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Tax Attorney in Tampa, FL

Federal IRS representation for Tampa individuals and businesses — audits, back taxes, liens, levies, payroll-tax disputes, FBAR disclosures, and U.S. Tax Court litigation at the Sam M. Gibbons Federal Courthouse on N. Florida Avenue. We also coordinate Florida Department of Revenue matters under IRS Form 2848 and Florida Form DR-835 Power of Attorney where they sit alongside a federal case.

Reviewed by Parham Khorsandi, Esq. — California Bar #266658. Last reviewed: .

Serving Hillsborough County, Pinellas, Pasco, Hernando, and the greater Tampa Bay area

$100M+

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2,000+

resolved cases

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U.S. Tax Court

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If you owe back taxes in Tampa, here is the 2026 picture

Florida has no state personal income tax — for individual Tampa taxpayers, the entire income-tax exposure sits at the federal level under IRC Subtitle A. The state tax picture is built around three other pieces: a 5.5% Florida Corporate Income Tax under Fla. Stat. ch. 220 (with the limited exemption for entities taxed as partnerships or S-corps); 6% state sales and use tax plus a 1.5% Hillsborough County discretionary surtax for a 7.5% combined rate in Tampa under Fla. Stat. ch. 212; and Florida Documentary Stamp Tax on deeds and notes under Fla. Stat. ch. 201. Disputes with the Florida Department of Revenue run through informal protest with the Department, then formal administrative appeal at the Division of Administrative Hearings under Fla. Stat. ch. 120.

If you have received an IRS CP504, an LT11 Final Notice of Intent to Levy, a Statutory Notice of Deficiency, or a Florida DOR Notice of Proposed Assessment or Notice of Decision, the deadlines are short. We pull your IRS account transcripts, calculate your Collection Statute Expiration Date under IRC § 6502, file Form 2848 Power of Attorney with the IRS and Form DR-835 with the Florida DOR, and put administrative brakes on collection while the case is built.

Federal tax representation for Tampa Bay taxpayers

Victory Tax Lawyers, LLP is a California-Bar-admitted tax-resolution law firm based in Los Angeles. Our federal practice runs nationwide. The Internal Revenue Service accepts our Form 2848 Power of Attorney in every state, and the U.S. Tax Court — a single federal tribunal with jurisdiction over IRS deficiency cases under IRC § 6213(a) — holds regular trial sessions in Tampa at the Sam M. Gibbons U.S. Courthouse. From our Robertson Boulevard office in Los Angeles, we represent Tampa-area residents and Florida-domiciled businesses in IRS audits, collection cases, Tax Court petitions, Offers in Compromise under IRC § 7122, Installment Agreements under IRC § 6159, lien discharges under IRC § 6325, levy releases under IRC § 6343, FBAR disclosures under 31 U.S.C. § 5314, and Trust Fund Recovery Penalty defenses under IRC § 6672.

For Florida state tax matters — the 5.5% Florida Corporate Income Tax under Fla. Stat. ch. 220, sales and use tax disputes under Fla. Stat. ch. 212 (6% state plus 1.5% Hillsborough discretionary, total 7.5% in Tampa), documentary stamp tax under Fla. Stat. ch. 201, reemployment (unemployment) tax under Fla. Stat. ch. 443, and contested matters headed to the Division of Administrative Hearings (DOAH) — we file Form DR-835 Power of Attorney with the Department of Revenue and handle the administrative protest track directly. For formal litigation at DOAH, in Florida circuit court, or in the Florida District Courts of Appeal, we coordinate with locally admitted Florida counsel under a co-counsel arrangement. The federal portion of the engagement — usually the larger exposure for high-income Tampa taxpayers, given Florida's absence of personal income tax — stays with our firm.

Tampa sits at the intersection of several distinct tax-exposure economies: U.S. Central Command and U.S. Special Operations Command headquartered at MacDill Air Force Base (combat-zone exclusions under IRC § 112, deadline tolling under IRC § 7508, MSRRA spouse-residency elections, SCRA protections); Port Tampa Bay (Florida's largest seaport by tonnage) and Tampa International Airport (cruise homeporting for Carnival and Royal Caribbean, plus shipping and logistics with foreign accounts that drive FBAR exposure); a Big Law and insurance back-office corridor (Shumaker, Trenam, Citi, JPMorgan, plus a heavy partner-level § 199A SSTB analysis); the Tampa Bay Buccaneers, Lightning, and Rays (pro-athlete domicile elections leaning on Florida's no-PIT status, plus jock-tax allocation under IRC § 61); the Tampa General Hospital, Moffitt Cancer Center, AdventHealth, and BayCare medical anchors (1099 physician contracts, Stark and anti-kickback overlays); the post-2020 NY/SF migration into Tampa tech (RSU and ISO underwithholding); Cuban-American and Puerto Rican communities concentrated in Ybor City and Town ‘n’ Country (FBAR for foreign-held accounts, ITIN W-7 applications, treaty positions); and a real-estate boom across Treasure Island, Clearwater Beach, and St. Pete Beach that produced a wave of IRC § 1031 exchanges, IRC § 121 home-sale exclusions, and short-term-rental classification fights under IRC § 280A. Hurricanes Ian (2022), Idalia (2023), Helene (2024), and Milton (2024) layered casualty-loss claims under IRC § 165(h), involuntary-conversion deferrals under IRC § 1033, and deadline tolling under IRC § 7508A on top of every existing case. The federal procedures are uniform; the facts are Tampa-specific.

Your tax rights as a Tampa taxpayer

Two parallel rights frameworks apply when you owe tax. Federal rights come from the Internal Revenue Code and IRS Publication 1, the Taxpayer Bill of Rights. State rights for Florida taxpayers come from the Florida Taxpayer's Bill of Rights at Fla. Stat. § 213.015, administered through the Florida Department of Revenue, and from the Administrative Procedure Act at Fla. Stat. ch. 120, which governs how a disputed Florida DOR assessment reaches the Division of Administrative Hearings. Knowing both is the difference between a clean resolution and a missed 60-day DOAH petition window that ends in a final Florida assessment against your Tampa business or property.

Right to representation

IRC § 7521(b)(2) and (c) give you the right to be represented by an attorney, CPA, or Enrolled Agent during any IRS examination or interview. Once Form 2848 is on file, the IRS routes communication through us, not you. Florida mirrors this through Form DR-835 Power of Attorney filed with the Florida Department of Revenue.

Right to U.S. Tax Court review

IRC § 6213(a) gives you 90 days from a Statutory Notice of Deficiency to petition the U.S. Tax Court without paying the tax first. Miss the 90 days and the federal assessment becomes final. The Tax Court holds regular trial sessions in Tampa at the Sam M. Gibbons U.S. Courthouse, 801 N Florida Avenue.

Florida Taxpayer's Bill of Rights

Fla. Stat. § 213.015 codifies twenty enumerated rights, including the right to written notice of audit findings, the right to an informal protest with the Florida DOR within 60 days of a Notice of Proposed Assessment, and the right to confidentiality of taxpayer information under Fla. Stat. § 213.053.

Right to DOAH review

Fla. Stat. § 72.011 and Fla. Stat. ch. 120 give a Florida taxpayer the choice, after a final Florida DOR Notice of Decision, to challenge the assessment either in circuit court (paying or bonding the tax under Fla. Stat. § 72.011(3)) or through an administrative proceeding at the Division of Administrative Hearings, 1230 Apalachee Parkway, Tallahassee. The petition deadline is 60 days from the Notice of Decision.

Collection Due Process

IRC § 6320 (lien) and IRC § 6330 (levy) give you a 30-day window to request a CDP hearing once the IRS files a Notice of Federal Tax Lien or issues a Final Notice of Intent to Levy. A timely Form 12153 filing halts collection and preserves judicial review through the U.S. Tax Court.

Right to settle for less than owed

Federally, IRC § 7122 authorizes Offers in Compromise based on doubt as to liability, doubt as to collectibility, or effective tax administration. Florida runs a parallel compromise authority under Fla. Stat. § 213.21, allowing the Department of Revenue to compromise penalties and, in narrower circumstances, tax based on doubt or hardship. Both programs require filing compliance before consideration.

Right to combat-zone protections

For MacDill-stationed servicemembers and their families, IRC § 112 excludes combat-zone compensation from gross income, IRC § 7508 tolls filing and payment deadlines for the period of service plus 180 days, and the Servicemembers Civil Relief Act caps interest at 6% on pre-service obligations. The Military Spouses Residency Relief Act lets the spouse claim a home-of-record state for income-tax purposes.

Right to recover fees

IRC § 7430 allows recovery of administrative and litigation costs if the IRS takes a position that is not substantially justified and the taxpayer prevails. The threshold is high but real — we see it most often in audit reconsideration cases and Innocent Spouse relief matters under IRC § 6015.

How Victory Tax Lawyers helps Tampa taxpayers

Offer in Compromise under IRC § 7122

We file Form 656 with Form 433-A(OIC) or 433-B(OIC), document the Reasonable Collection Potential, and negotiate doubt-as-to-collectibility offers when full collection is not feasible within the remaining CSED. For Tampa taxpayers, the federal OIC is usually the entire compromise story — Florida has no personal income tax to settle. Where a Florida sales-tax, reemployment-tax, or corporate income tax balance is also outstanding, we run a Fla. Stat. § 213.21 compromise request on a parallel track.

Installment Agreements under IRC § 6159

Streamlined IAs (under $50,000), partial-pay IAs under IRC § 6159(d), and full-pay agreements. We push for partial-pay structures where the IRC § 6502 ten-year CSED will extinguish the balance before payoff — an under-used resolution path for Tampa taxpayers in the $50,000 to $250,000 federal-debt range.

Lien discharge, subordination, and withdrawal

When a Notice of Federal Tax Lien blocks a Tampa property sale or refinance, we file Form 14135 (discharge), Form 14134 (subordination), or Form 12277 (withdrawal). NFTLs are filed with the Hillsborough County Clerk of Court (and the Pinellas, Pasco, or Hernando County Clerks for those metro segments) and encumber title until cleared under IRC § 6325. Timing must align with the closing.

Levy release under IRC § 6343

Wage levies, bank levies on Truist, Bank of America, Wells Fargo, Fifth Third, Raymond James Bank, or any Florida-licensed institution, and accounts-receivable levies on Tampa contractors. We document economic hardship under IRC § 6343(a)(1)(D) and Treasury Reg. § 301.6343-1(b)(4), and where the levy is procedurally defective we challenge it through Collection Due Process or Appeals. Florida sales-tax warrants follow a parallel state track under Fla. Stat. § 213.69.

Audit defense and U.S. Tax Court litigation

Correspondence audits, office audits, and field examinations — including sensitive issues like cryptocurrency, foreign accounts under FinCEN Form 114 (FBAR), S-corporation reasonable-compensation, short-term-rental classification on Treasure Island and St. Pete Beach properties, and casualty-loss claims from the 2022-2024 hurricane sequence. If the audit closes unfavorably, we petition the U.S. Tax Court within the 90-day IRC § 6213(a) window. Tampa trial sessions are held at the Sam M. Gibbons U.S. Courthouse.

Penalty abatement under IRC § 6651 and IRM 20.1.1

First-Time Abate administrative relief, reasonable-cause abatement, and statutory exceptions for failure-to-file and failure-to-pay penalties. On accuracy-related penalties under IRC § 6662, we document substantial authority or adequate disclosure to defeat the assessment. Florida sales-tax and reemployment-tax penalties under Fla. Stat. § 213.21 follow a separate reasonable-cause analysis administered through the Florida DOR.

Twelve types of Tampa tax matters we handle

Federal cases for Tampa-area residents and businesses, framed against the Florida DOR overlay where it matters.

Combat-zone tax issues at MacDill AFB

MacDill is the headquarters of U.S. Central Command and U.S. Special Operations Command. IRC § 112 excludes combat-zone compensation from gross income; IRC § 7508 tolls filing and payment deadlines for the period of service plus 180 days. We resolve assessments that ignored the § 7508 toll and rebuild correctly-coded returns for servicemembers redeployed back to Tampa.

Trust Fund Recovery Penalty

IRC § 6672 imposes personal liability on officers, partners, and check-signers for unpaid employment-tax withholding. Tampa restaurant, hospitality, marine-services, construction, and trucking owners are common targets. The IRS uses Form 4180 interviews to identify responsible persons; Florida parallels this with reemployment-tax personal liability under Fla. Stat. § 443.141.

FBAR and FATCA non-disclosure

FinCEN Form 114 for foreign accounts over $10,000 aggregate is a frequent Tampa engagement — the Cuban-American population in Ybor City and Town ‘n’ Country, the Puerto Rican community across South Tampa, and shipping-and-cruise income flowing through Caribbean and Latin American banking all drive Streamlined Filing Compliance Procedures and Delinquent FBAR Submission cases under 31 U.S.C. § 5314.

Short-term-rental classification

Treasure Island, Clearwater Beach, St. Pete Beach, Davis Islands, and Harbour Island short-term rentals raise the seven-day average-rental-period rule of Treas. Reg. § 1.469-1T(e)(3)(ii) and the IRC § 280A vacation-home limitations. Florida adds a transient rental tax under Fla. Stat. § 212.03 (combined 13% in Hillsborough including the tourist development tax). Misclassification creates both federal passive-activity disallowance and a state tax assessment.

Casualty losses from Ian, Idalia, Helene, Milton

Hurricanes Ian (2022), Idalia (2023), Helene (2024), and Milton (2024) devastated Tampa Bay storm-surge zones. IRC § 165(h) limits personal casualty losses to federally declared disaster areas; IRC § 1033 defers gain on involuntary conversions when insurance or FEMA proceeds exceed basis; IRC § 7508A tolls filing and payment deadlines. We sort the timing of basis-recovery, insurance-proceed, and disaster-loss carrybacks.

Notice of Federal Tax Lien

NFTLs filed with the Hillsborough County Clerk of Court (601 E Kennedy Blvd) encumber title to Tampa real property and trigger CDP rights under IRC § 6320. Pinellas, Pasco, and Hernando filings cover the rest of the metro. Florida's homestead exemption under Fla. Const. art. X, § 4 protects against state-creditor execution but does not block a federal tax lien — the supremacy of federal tax liens over state homestead protections is settled under United States v. Rodgers.

Pro-athlete jock-tax allocation

Tampa Bay Buccaneers, Lightning, and Rays players claim Florida domicile precisely because Florida has no state personal income tax. Away-game days still create source-state income subject to jock-tax allocation under IRC § 61. We coordinate the duty-day allocation, defend the Florida domicile election against challenges from California, New York, and other source-state revenue departments, and resolve any resulting federal underpayment under IRC § 6654.

RSU and ISO underwithholding

The post-2020 New York and San Francisco migration into Tampa brought a heavy population of remote tech workers with employer equity. RSU vest events generate W-2 inclusion taxed at the 22% supplemental rate — well below a 32%, 35%, or 37% marginal rate. ISO disqualifying dispositions trigger AMT under IRC § 55. Because Florida has no PIT, the underwithholding fix is purely federal: W-4 adjustment plus Form 1040-ES under IRC § 6654.

Section 199A and SSTB analysis

Tampa's Big Law presence (Shumaker, Trenam, Holland & Knight, and others), plus large insurance back-office operations, drives a steady volume of partner-level IRC § 199A specified-service-trade-or-business analyses. The wage-and-UBIA limits, the phase-in thresholds (currently $241,950 single / $383,900 joint for 2025), and the SSTB definition under Treas. Reg. § 1.199A-5 are the live issues we defend on audit.

1099 physician income

Tampa General Hospital, AdventHealth Tampa, BayCare Health System, and Moffitt Cancer Center contract heavily with 1099 physicians and locum-tenens providers. Self-employment tax at 15.3%, quarterly estimated payments under IRC § 6654, retirement-plan structuring (solo 401(k) or defined-benefit), and the Stark and anti-kickback compliance overlay all matter when a physician's federal balance crosses six figures.

Florida sales and use tax disputes

Florida sales and use tax under Fla. Stat. ch. 212 runs at 6% state plus 1.5% Hillsborough discretionary surtax for a 7.5% combined rate in Tampa. Audits hit restaurants, marine dealers, used-car dealers, contractors, and online sellers. The Florida DOR Notice of Proposed Assessment opens a 60-day informal protest window; an unresolved protest produces a Notice of Decision that opens the 60-day DOAH or circuit-court window under Fla. Stat. § 72.011.

Passport revocation under IRC § 7345

A seriously delinquent tax debt (over $62,000 for 2025, indexed annually) triggers State Department certification and passport hold. With Tampa International Airport's heavy international traffic to Latin America and Europe, plus the cruise homeporting at Port Tampa Bay, passport-revoked taxpayers lose business and family travel overnight. We file the IRC § 7345(e) action to reverse the certification.

Nine common causes of tax debt for Tampa taxpayers

Patterns we see repeatedly in Tampa Bay engagements. None of them are unusual — all of them are resolvable.

1. Self-employment underpayment

Locum-tenens physicians at Tampa General and Moffitt, real-estate agents along the Gulf coast, charter-boat captains out of Tampa Bay, and consultants file Schedule C or K-1 income with no estimated-tax payments. The first IRS CP14 lands the following spring with penalties under IRC § 6654.

2. Hurricane-driven cash crunch

Ian, Idalia, Helene, and Milton interrupted operations for Tampa Bay restaurants, marine businesses, and Gulf-front rentals. Even with IRC § 7508A deadline tolling, the next-cycle payroll, sales-tax, and quarterly estimated obligations come due before insurance proceeds clear. The result is a federal § 6672 trust-fund file and a Florida sales-tax warrant.

3. Business closure

When a Tampa LLC or S-corp closes with unpaid Form 941 payroll-tax balances, IRC § 6672 follows the responsible officer personally — well after the entity is dissolved. Florida reemployment-tax personal liability under Fla. Stat. § 443.141 mirrors the federal trust-fund framework.

4. Divorce and joint-return fallout

A jointly-filed return tied to a now-former spouse's understatement leaves both parties liable until Innocent Spouse relief under IRC § 6015 is granted. Florida is a non-community-property state, which simplifies allocation compared with California-based cases but does not change the federal joint-and-several liability rule.

5. Identity theft and fraudulent returns

A return filed in your name with refund redirected. Form 14039 opens the IRS identity-theft case; the assessment must be corrected, not just protested. Florida sees a higher rate of refund fraud than most states because of its retiree population.

6. Cryptocurrency CP2000 surprise

Exchanges issue Form 1099-DA (introduced 2025), and the IRS computer matches reported gains. Missed basis records turn into ordinary-income assessments at the full sale price. Tampa's tech-migration population over-indexes on crypto exposure.

7. Late-filed or unfiled returns

Failure-to-file under IRC § 6651(a)(1) compounds at 5% per month, capped at 25%. After three years, refunds are barred under IRC § 6511. Servicemembers redeployed from Central Command theaters frequently return to find IRS Substitute-for-Return assessments under IRC § 6020(b) on the books even though IRC § 7508 should have tolled the deadline.

8. Real-estate sale without estimated tax

A South Tampa, Davis Islands, Harbour Island, or beach-front sale generating substantial capital gain, with no Form 1040-ES payment, produces a tax bill the next April. Investor flips taxed at ordinary-income rates — not capital-gain — under the dealer-status rules. Florida Documentary Stamp Tax under Fla. Stat. ch. 201 adds a state cost at closing.

9. Stock-option exercise without planning

ISO disqualifying dispositions and NSO ordinary-income inclusions hit Tampa tech transplants, Citi and JPMorgan back-office partners, and Big Law associates with AMT under IRC § 55 and large balances due. Florida's no-PIT status means the entire planning fight lives at the federal level.

Eight tax liabilities that pull in Tampa taxpayers

Federal authority alongside the Florida statute where there is a parallel.

Failure to file federal return

IRC § 6651(a)(1) imposes 5%/month, max 25%, plus interest under IRC § 6601. Florida has no personal income tax, so there is no state-PIT failure-to-file analog. The Florida DOR's analogous penalties live in sales tax, corporate income tax, and reemployment tax under Fla. Stat. § 213.21.

Florida Corporate Income Tax

Fla. Stat. ch. 220 imposes a 5.5% Florida Corporate Income Tax on C-corporation taxable income, with the first $50,000 of net income exempt. Pass-through entities taxed as partnerships or S-corps are generally exempt at the state level. A late-filed Florida F-1120 triggers 10% per month failure-to-file penalty up to 50% under Fla. Stat. § 220.803.

Federal § 7122 Offer in Compromise eligibility

All federal returns must be filed (IRC § 7122(d) compliance) and the offer must reflect Reasonable Collection Potential. The non-refundable $205 application fee may be waived for low-income certified offers.

Florida sales and use tax

Fla. Stat. ch. 212 imposes 6% state plus a 1.5% Hillsborough discretionary surtax, total 7.5% in Tampa. Personal liability for responsible persons under Fla. Stat. § 213.29 pierces the corporate veil for trust-fund sales tax. The transient rental tax under Fla. Stat. § 212.03 adds another layer on short-term lodging in Hillsborough.

Trust Fund Recovery Penalty

IRC § 6672 imposes 100% personal liability on responsible persons for unpaid trust-fund employment tax. Florida applies a similar responsible-person rule to reemployment-tax withholding under Fla. Stat. § 443.141 and to sales-tax collection under Fla. Stat. § 213.29.

Accuracy-related penalty

IRC § 6662 imposes 20% on substantial-understatement or negligence; IRC § 6663 imposes 75% on fraud. Defense is built on substantial authority, adequate disclosure, or reasonable cause.

Florida Documentary Stamp Tax

Fla. Stat. ch. 201 imposes a documentary stamp tax on deeds, notes, and other written obligations — $0.70 per $100 of consideration on deeds outside Miami-Dade and $0.35 per $100 on the note. Failure-to-pay penalties under Fla. Stat. § 213.21 apply; closings on Tampa real estate that omitted the stamp produce a later DOR assessment against the grantee.

Transferee liability

IRC § 6901 lets the IRS pursue a transferee — a person who received property from a delinquent taxpayer — for the transferor's unpaid tax, up to the value of the transferred property. Routine in Tampa divorce, business-sale, and inheritance fact patterns.

What resolution can look like

Debt reduced

An accepted IRC § 7122 Offer in Compromise can resolve six-figure balances for a fraction of the original assessment where Reasonable Collection Potential supports the offer. National acceptance is roughly one in three; preparation determines the outcome.

Penalties abated

First-Time Abate removes a single year of failure-to-file or failure-to-pay penalties for taxpayers with a clean three-year compliance record. Reasonable-cause abatement under IRM 20.1.1 reaches further when supported by documentation — hurricane disruption, deployment, medical emergency.

Lien released or withdrawn

Once a debt is paid in full, the IRS releases the Notice of Federal Tax Lien within 30 days per IRC § 6325(a). On an Installment Agreement of $25,000 or less, lien withdrawal under Form 12277 can be requested to clear title with the Hillsborough County Clerk.

Sample tax-resolution outcomes

Anonymized client matters drawn from our $100M+ aggregate tax-relief record across 2,000+ resolved cases.

Year Tax debt Resolution Final outcome
2024 $152,296 IRC § 6159 Installment Agreement Accepted at $25/month, partial-pay
2024 $138,296 Streamlined Installment Agreement Accepted at $25/month
2023 $130,555 Partial-Pay Installment Agreement Accepted at $50/month
2023 $128,206 IRC § 6159 Installment Agreement Accepted at $25/month
2022 $116,451 Partial-Pay Installment Agreement Accepted at $50/month

Past results do not guarantee future outcomes. Each tax case is unique. Results depend on the specific facts of the matter, including the taxpayer's financial condition, compliance history, and the discretion of the Internal Revenue Service and the Florida Department of Revenue.

Why Victory Tax Lawyers for a Tampa federal-tax case

Victory Tax Lawyers is California-Bar-admitted, not Florida-Bar-admitted. That distinction matters — and it does not block our work. The U.S. Tax Court is a federal court with nationwide jurisdiction; an attorney admitted to that court may petition and try cases at any of its trial locations, including Tampa at the Sam M. Gibbons U.S. Courthouse. IRS administrative practice runs on Form 2848 Power of Attorney, accepted from any attorney in good standing with any state bar plus an active Centralized Authorization File number. Most of our Tampa clients never need a separately admitted Florida attorney because the case is, at its core, federal. Florida's lack of a state personal income tax pushes that reality even further than in Georgia or California: for an individual Tampa taxpayer, the income-tax fight is almost always federal-only.

For administrative work before the Florida Department of Revenue — sales-tax protests, corporate income tax audits, reemployment-tax audits, documentary stamp tax assessments, and compromise requests under Fla. Stat. § 213.21 — we file Form DR-835 Power of Attorney and handle the matter remotely. When a case must move to the Division of Administrative Hearings (DOAH, seated at 1230 Apalachee Parkway, Tallahassee), to circuit court under Fla. Stat. § 72.011, or to one of the Florida District Courts of Appeal, we coordinate with locally admitted Florida counsel under a co-counsel arrangement. The federal portion of the engagement — usually the larger exposure — stays with our firm.

What distinguishes our firm: a California-Bar-admitted managing attorney with active U.S. Tax Court admission, an Enrolled Agent on staff for IRS administrative work, a 5.0 / 72-review Google rating, and $100M+ in cumulative tax relief secured across 2,000+ resolved matters. No marketing claim of being a Florida-licensed firm — we are not. A factually accurate offer of federal tax representation, available to any Tampa Bay taxpayer, at the same standard we apply to a Los Angeles client. Our 100% remote workflow runs through a secure document portal — you never have to drive across the Howard Frankland or the Sunshine Skyway.

Our seven-step process for Tampa clients

1

Free consultation

A 30-minute call with a tax attorney to scope your matter, identify deadlines, and decide whether engagement is the right move.

2

Engagement letter

A written scope, fee structure, and conflict check. Flat fees for administrative resolution; hourly or hybrid for litigation.

3

Form 2848 and CAF

We file the federal Power of Attorney with the IRS and Form DR-835 with the Florida DOR, register on the CAF system, and step in as the contact of record.

4

Transcript and CSED analysis

We pull IRS account transcripts via Form 8821, calculate each year's CSED under IRC § 6502, identify tolling events, and confirm any IRC § 7508 or § 7508A toll for combat-zone service or hurricane disasters.

5

Strategy memo

A written summary: the resolution path (OIC, IA, CNC, audit response, CDP, Tax Court), the timeline, and the realistic outcome range.

6

Filing and negotiation

We file the operative document — Form 656, Form 433-A(OIC), Form 9423, Form 12153, a Florida DOR informal protest, or a DOAH petition through local counsel — and handle every IRS and Florida DOR contact.

7

Compliance monitoring

After resolution we monitor compliance through the OIC five-year terms or the IA term, file future returns, and prevent default.

Two collection clocks: federal CSED and Florida's parallel statutes

The IRS has ten years from the date of assessment to collect a federal tax under IRC § 6502. After the Collection Statute Expiration Date, the debt is extinguished by operation of law. The clock pauses (“tolls”) when an Offer in Compromise is pending, when a Collection Due Process petition is filed, during bankruptcy, when an installment agreement is requested, when the taxpayer is outside the United States for six months or more, and (for MacDill servicemembers) during qualifying combat-zone service plus 180 days under IRC § 7508. Hurricane-driven postponements under IRC § 7508A toll filing and payment deadlines but generally do not toll the collection statute itself — verify each year on transcript.

Florida runs separate state limitations rules. The Florida DOR generally has three years from the return due date to assess tax under Fla. Stat. § 95.091, extended to six years for substantial understatement or unreported sales, and without limit for fraud or unfiled returns. Once a tax warrant is recorded under Fla. Stat. § 213.731, collection runs for twenty years from the date of recording under Fla. Stat. § 95.091(1)(b). The federal ten-year CSED and Florida twenty-year warrant clock often produce a situation where the federal debt extinguishes years before the state warrant does — particularly relevant for Tampa businesses with both an unpaid Form 941 federal balance and an open Florida sales-tax warrant. Pull both records and know both dates before agreeing to any payment plan or amended return that could restart a clock.

Tampa tax authorities and venues

A working knowledge of the tribunals, agencies, and field offices around Tampa Bay is what separates an answered Notice from a wage levy. Below is the working list our firm uses on every Tampa matter.

Internal Revenue Service — Tampa TAC

The federal tax authority, at irs.gov. The Tampa Taxpayer Assistance Center operates at 3848 W Columbus Drive, Tampa FL 33607. Appointments are required for in-person service. Pull account transcripts via Form 8821 or through the practitioner e-services portal.

U.S. Tax Court — Tampa trial sessions

The U.S. Tax Court holds regular trial sessions in Tampa at the Sam M. Gibbons U.S. Courthouse, 801 N Florida Avenue, Tampa FL 33602. Tampa is the primary Florida trial city for the Tax Court. Petitions are filed electronically through DAWSON at ustaxcourt.gov; the 90-day deadline runs from the IRS Statutory Notice of Deficiency under IRC § 6213(a).

U.S. District Court — Middle District of Florida, Tampa Division

Refund suits filed after payment of tax and exhaustion of administrative remedies under IRC § 7422 may be brought in the U.S. District Court for the Middle District of Florida, Tampa Division, 801 N Florida Avenue, Tampa FL 33602, or in the U.S. Court of Federal Claims in Washington, D.C.

Florida Department of Revenue

The state tax authority, at floridarevenue.com. Headquartered at 5050 W Tennessee Street, Tallahassee FL 32399, with Tampa-area service centers serving Hillsborough, Pinellas, Pasco, and Hernando taxpayers. Administers the 5.5% Florida Corporate Income Tax, 6% state sales tax, documentary stamp tax, reemployment tax, and the compromise authority under Fla. Stat. § 213.21.

Division of Administrative Hearings (DOAH)

The administrative forum for contested Florida tax assessments under Fla. Stat. ch. 120, seated at 1230 Apalachee Parkway, Tallahassee FL 32399. After a final Florida DOR Notice of Decision, a taxpayer has 60 days under Fla. Stat. § 72.011 to elect DOAH review or, alternatively, to challenge the assessment in circuit court (paying or bonding the tax). DOAH proceedings are conducted by Administrative Law Judges and produce a recommended order; the DOR issues the final order.

Hillsborough County Tax Collector

The county tax authority for Tampa proper. Main office at 601 E Kennedy Boulevard, Tampa FL 33602. Page: hillstax.org. Administers Hillsborough County property-tax billing and collection, business tax receipts, and other county-level revenue measures. NFTLs filed with the Hillsborough County Clerk of Court (same address) encumber Tampa real property.

Hillsborough County Property Appraiser

Office at 601 E Kennedy Boulevard, Tampa FL 33602. Sets assessed value, administers the Florida homestead exemption under Fla. Const. art. X, § 4 and the Save Our Homes 3% assessment cap under Fla. Const. art. VII, § 4(d). Value disputes are heard before the Hillsborough Value Adjustment Board within 25 days of the TRIM notice.

City of Tampa Revenue and Finance

The municipal finance office, at 306 E Jackson Street, Tampa FL 33602. Administers City of Tampa business tax receipts, communications service tax remittance, and other city-level revenue separate from county property tax.

IRS Independent Office of Appeals

The administrative-appeals body within the IRS that resolves cases without litigation. Tampa cases run through the Appeals offices serving the Southeast region. Filings: Form 9423 (collection appeal) and Form 12153 (CDP). Page: irs.gov/appeals.

Taxpayer Advocate Service — Tampa

An independent organization within the IRS that helps when normal channels stall. The Tampa TAS office serves taxpayers across the Middle District of Florida. Page: taxpayeradvocate.irs.gov.

Speak with a tax attorney about your Tampa matter

Free consultation, attorney-client privileged, no obligation. If a Notice of Deficiency, a Final Notice of Intent to Levy, or a Florida DOR Notice of Proposed Assessment is in front of you, the deadline to respond is real and short — call today.

Call (800) 883-8301 Free Consultation

Frequently asked questions — Tampa tax

Does Florida have a state income tax?

No state personal income tax. Fla. Const. art. VII, § 5 prohibits a state income tax on natural persons without a constitutional amendment. The Florida tax structure rests on a 5.5% Florida Corporate Income Tax under Fla. Stat. ch. 220 (with the first $50,000 of net income exempt and pass-through entities generally exempt), 6% state sales and use tax plus local discretionary surtaxes (7.5% combined in Tampa with the Hillsborough 1.5% add-on), documentary stamp tax under Fla. Stat. ch. 201, reemployment (unemployment) tax under Fla. Stat. ch. 443, and a small list of excise taxes. For most individual Tampa taxpayers, the entire income-tax exposure is federal.

Where is the closest U.S. Tax Court trial location to Tampa?

The U.S. Tax Court holds regular trial sessions in Tampa itself at the Sam M. Gibbons U.S. Courthouse, 801 N Florida Avenue. Tampa is the primary Florida trial city for the Tax Court. A taxpayer anywhere in the Middle District of Florida (Hillsborough, Pinellas, Pasco, Hernando, Manatee, Sarasota, and surrounding counties) can request the Tampa trial location when filing the Tax Court petition. Petitions are filed electronically through DAWSON at ustaxcourt.gov; the 90-day deadline from the IRS Statutory Notice of Deficiency under IRC § 6213(a) is jurisdictional — a single day late and the federal assessment becomes final.

How do I challenge a Florida DOR sales-tax assessment?

A Florida DOR audit produces a Notice of Intent to Make Audit Changes (often called the “DR-840”), followed by a Notice of Proposed Assessment if the taxpayer does not resolve at the audit level. The Proposed Assessment opens a 60-day window to file an informal protest with the Florida DOR Technical Assistance and Dispute Resolution group. If the protest is denied, the DOR issues a Notice of Decision (or Notice of Reconsideration). Under Fla. Stat. § 72.011, the taxpayer then has 60 days to elect either a DOAH administrative proceeding under Fla. Stat. ch. 120 or a circuit-court action (paying or bonding the contested tax). We handle the protest stage directly under Form DR-835 and coordinate Florida counsel for the DOAH or circuit-court stage.

What is Florida's collection statute of limitations?

Fla. Stat. § 95.091 gives the Florida DOR three years from a return's due date to assess tax (six years for substantial understatement, with no limit for fraud or unfiled returns). Once a Florida tax warrant is recorded under Fla. Stat. § 213.731, collection runs for twenty years from the date of recording under Fla. Stat. § 95.091(1)(b). The federal CSED under IRC § 6502 is a separate ten-year clock running from the federal assessment date. A Tampa taxpayer with both a federal payroll-tax balance and a Florida sales-tax warrant routinely sees the federal debt extinguish years before the state warrant does.

Can I be audited by both the IRS and the Florida DOR for the same year?

Yes, though the practical overlap is narrower than in income-tax states. The IRS audits federal income-tax returns; the Florida DOR audits Florida Corporate Income Tax (for C-corps), sales and use tax, reemployment tax, documentary stamp tax, and similar state taxes. Information is exchanged through the IRS-state exchange program. A federal employment-tax audit that establishes worker misclassification will often produce a parallel Florida reemployment-tax audit. A federal corporate income tax adjustment routinely produces a parallel F-1120 amendment requirement under the federal-change reporting rule.

Does Florida offer an Offer in Compromise equivalent to the federal program?

Florida's compromise authority is narrower than the federal program. Under Fla. Stat. § 213.21, the Department of Revenue may compromise penalties on a showing of reasonable cause, and may compromise tax in limited circumstances tied to doubt as to liability or, more rarely, doubt as to collectibility. The state has no broad equivalent to the federal IRC § 7122 doubt-as-to-collectibility OIC program, but penalty compromise is routinely available, and stipulated time payments are common. We typically run a federal Offer in Compromise alongside a Florida penalty-compromise request where both debts are real.

I'm an active-duty servicemember at MacDill — what tax protections apply to me?

Four federal frameworks routinely matter. IRC § 112 excludes combat-zone compensation from gross income for enlisted personnel and warrant officers; commissioned officers receive the exclusion up to the highest enlisted-pay level plus imminent danger pay. IRC § 7508 tolls filing, payment, refund, and CSED deadlines for the period of combat-zone or contingency-operation service plus 180 days. The Servicemembers Civil Relief Act caps interest at 6% on pre-service obligations and stays civil judicial proceedings while the servicemember is on active duty. The Military Spouses Residency Relief Act lets the non-military spouse claim the servicemember's state of legal residence for income-tax purposes — for many MacDill families that means continuing to claim a no-PIT home of record like Texas or Florida even while the spouse works in another state.

My beach property took hurricane damage — how do I deduct the loss?

For Hurricanes Ian (2022), Idalia (2023), Helene (2024), and Milton (2024), all were federally declared disasters, which means IRC § 165(h) personal casualty losses are available for the unreimbursed portion above the $100 per-event floor and 10% of AGI threshold. Election under IRC § 165(i) allows the loss to be claimed on the prior year's return for faster refund. IRC § 1033 defers gain when insurance or FEMA proceeds exceed basis, provided qualifying replacement property is acquired within the statutory window (two years for personal-use, four years for business). IRC § 7508A tolls filing and payment deadlines for taxpayers in the disaster area. We coordinate the basis-recovery, gain-deferral, and timing pieces against the insurance settlement.

I own a short-term rental on Treasure Island or Clearwater Beach — what do I report?

Two layers. Federally, the seven-day average rental period rule under Treas. Reg. § 1.469-1T(e)(3)(ii) takes the activity out of the rental category and into the trade-or-business category, with passive-activity rules under IRC § 469 and material-participation testing. IRC § 280A vacation-home limitations apply when personal use exceeds the greater of 14 days or 10% of rental days. Schedule C vs Schedule E classification turns on whether substantial services are provided. On the state side, Florida transient rental tax under Fla. Stat. § 212.03 applies (6% state plus 5% Hillsborough tourist development tax for a combined 11% in Hillsborough on rentals of six months or less). Pinellas County (Treasure Island, Clearwater Beach, St. Pete Beach) and Pasco County have their own rates. Local zoning and registration rules add a third layer.

Can a California-Bar-admitted attorney represent me in Tampa?

For federal IRS matters — yes. The IRS accepts Form 2848 Power of Attorney from any attorney in good standing with any state bar. The U.S. Tax Court is a single federal court with nationwide jurisdiction; an attorney admitted to that court may represent a taxpayer at any Tax Court trial location, including Tampa. For Florida DOR administrative work, we file Form DR-835 Power of Attorney and handle the matter remotely. For DOAH litigation, Florida circuit-court actions under Fla. Stat. § 72.011, or appeals to the Florida District Courts of Appeal, we co-counsel with locally admitted Florida attorneys. Most engagements — audit defense, OIC, IA, levy release, FBAR disclosure, Tax Court — are federal and stay entirely with our firm.

What if I have unfiled returns going back several years?

The IRS Voluntary Filing Compliance policy and IRM 5.1.11.6 generally require the last six years of returns to bring a taxpayer back into compliance. Filing prior-year returns is the first step before any OIC, IA, or CNC request — IRC § 7122(d) compliance is a prerequisite for a federal Offer. Refunds claimed on returns filed more than three years after the original due date are time-barred under IRC § 6511(b)(2). For MacDill-stationed taxpayers, IRC § 7508 may toll the deadline materially — verify before treating any year as time-barred.

Can the IRS levy my Tampa bank account or wages?

Yes — after a Final Notice of Intent to Levy (CP90 or LT11) and expiration of the 30-day Collection Due Process window under IRC § 6330, the IRS may levy bank accounts at Truist, Bank of America, Wells Fargo, Fifth Third, Raymond James Bank, or any Florida-licensed institution and serve wage levies on Tampa employers. A timely Form 12153 CDP request halts collection while the case is reviewed by Appeals. After a CDP determination, the taxpayer has 30 days to petition the U.S. Tax Court under IRC § 6330(d)(1). Florida issues parallel state tax warrants under Fla. Stat. § 213.731 that work similarly through county clerk recording.

I'm a Buccaneers, Lightning, or Rays player domiciled in Tampa — how does jock tax work?

Florida domicile gives you a zero state personal income tax on Florida-source income, which is the planning value. But away games create source-state income subject to the destination state's nonresident allocation rules. The standard allocation is duty days — the proportion of total duty days spent in the source state, multiplied by total compensation. California, New York, and Illinois are aggressive enforcers. We coordinate the duty-day calculation, document the Florida domicile (driver license, voter registration, primary residence, Florida physician records, Florida business interests), and resolve any federal underpayment from the source-state withholding gap under IRC § 6654.

What is the difference between a federal Notice of Deficiency and a Florida DOR Notice of Proposed Assessment?

A federal Statutory Notice of Deficiency (the “90-day letter”) is the IRS's final pre-assessment notice; it triggers the 90-day U.S. Tax Court petition deadline under IRC § 6213(a). A Florida DOR Notice of Proposed Assessment is the state's initial post-audit assessment, opening a 60-day informal protest window. If the protest is denied, the DOR issues a Notice of Decision (or Notice of Reconsideration), which then opens the 60-day Fla. Stat. § 72.011 window to elect DOAH or circuit-court review. Missing either federal or state deadline forfeits the right to pre-payment hearing — post-payment remedies (federal refund suit under IRC § 7422 or Florida refund claim under Fla. Stat. § 215.26) remain, but the procedural posture changes.

How long does a federal Offer in Compromise take to process?

An IRS Offer in Compromise typically takes six to twelve months from filing to a final decision. The IRS deems an Offer accepted if not rejected within 24 months under IRC § 7122(f). While the OIC is pending, IRC § 6331(k) bars most levies, and the CSED is tolled. Rejected offers carry a 30-day Appeals window. A well-documented Offer with a complete Form 433-A(OIC) or 433-B(OIC) financial package moves faster than one returned for incompleteness.

Will hiring a tax attorney stop IRS collection action immediately?

Once Form 2848 is on file, the IRS routes all communication through the attorney and stops contacting the taxpayer directly. Active levies are not automatically lifted by the POA filing alone — release requires either a financial showing under IRC § 6343, a CDP filing under IRC § 6330, or an installment-agreement or OIC submission that triggers the IRC § 6331(k) collection bar. We move on those concurrently when a levy is in place. Florida state collection follows a similar pattern: a Form DR-835 routes state contact, and a pending compromise or stipulated time payment pauses warrant enforcement.

About the author

This page was written and reviewed by Parham Khorsandi, Esq., Managing Attorney of Victory Tax Lawyers, LLP. Cal Bar #266658. Admitted to practice before the United States Tax Court. Mr. Khorsandi has resolved over 2,000 federal tax matters and secured more than $100 million in tax relief for clients across all 50 states.

Page last reviewed: . Editorial standard: every federal-statute citation links to law.cornell.edu (Legal Information Institute, Cornell Law School). Every Florida statute citation references the Florida Statutes as published by the Florida Legislature. Every administrative authority links to its primary .gov source. Material changes to the law are reflected within 30 days of effective date.

Attorney Advertising. This page is provided by Victory Tax Lawyers, LLP for general informational purposes only. Nothing on this page constitutes legal advice, creates an attorney-client relationship, or substitutes for consultation with a licensed attorney about your specific tax matter. Prior results described or referenced do not guarantee a similar outcome. Each tax case turns on its individual facts, applicable law, and the discretion of the Internal Revenue Service, the Florida Department of Revenue, the U.S. Tax Court, the Division of Administrative Hearings, or other adjudicating body.

Victory Tax Lawyers, LLP is California-Bar-admitted with its principal office at 1100 S. Robertson Blvd., Los Angeles, CA 90035. The firm represents clients in federal tax matters nationwide via Form 2848 Power of Attorney and admission to the United States Tax Court. The firm is not admitted to practice in the courts of the State of Florida; where a Florida state-court appearance, DOAH proceeding, or appeal to a Florida District Court of Appeal is required, the firm associates with locally admitted Florida counsel.

IRS Circular 230 Disclosure: The discussion of U.S. federal tax issues on this page is not intended or written to be used, and cannot be used, for the purpose of avoiding penalties imposed under the Internal Revenue Code or for promoting, marketing, or recommending to another party any tax-related matters addressed. For specific tax advice, consult independent tax counsel.

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