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Tax Attorney in Toledo, OH

Federal IRS representation for Toledo individuals and businesses — audits, back taxes, liens, levies, Jeep / Stellantis Toledo Assembly Complex UAW and salaried RSU work, Owens-Illinois (O-I Glass), Dana Incorporated, and Marathon Petroleum refining equity disputes, ProMedica and Mercy Health St. Vincent 1099 physician files, University of Toledo academic appointments, Port of Toledo Great Lakes maritime payroll, FBAR for Lebanese-American, Bangladeshi, and Iraqi heritage accounts, and U.S. Tax Court litigation at Toledo trial sessions or the Cleveland Howard M. Metzenbaum U.S. Courthouse 130 miles east. We coordinate Ohio Department of Taxation matters under Ohio TBOR-1 Declaration of Tax Representative, handle the Toledo 2.5% municipal income tax administered by the City of Toledo Income Tax Division directly, work Michigan-Ohio cross-border wage allocation under the MI-OH reciprocity agreement, and refer Ohio Board of Tax Appeals litigation to locally admitted Ohio counsel under a co-counsel arrangement.

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Serving Lucas County, Wood, Ottawa, Sandusky, Fulton, Henry, and metro Toledo

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If you owe back taxes in Toledo, here is what shapes your 2026 case

Ohio operates a graduated personal income tax with rates from 0% to 3.5% under Ohio Revised Code § 5747.02, the product of a multi-year flat-rate phase-down enacted through Am. Sub. H.B. 33 and subsequent budget bills. Corporate income is taxed indirectly through the 0.26% Commercial Activity Tax (CAT) on gross receipts under R.C. Ch. 5751 — Ohio has no traditional corporate income tax. State sales tax is 5.75% under R.C. § 5739.02; Lucas County stacks a 1% permissive sales tax under R.C. § 5739.021 plus the Toledo Area Regional Transit Authority (TARTA) 0.5% transit tax under R.C. § 5739.023, bringing the combined Toledo sales-tax rate to 7.25%. On top of all of that, the City of Toledo imposes a 2.5% municipal income tax under Toledo Municipal Code Ch. 1905, administered by the City of Toledo Income Tax Division at 1 Government Center, Suite 2000.

If you have received an IRS CP504, LT11, or Statutory Notice of Deficiency, or if the Ohio Department of Taxation has issued a Notice of Assessment under R.C. § 5747.13, the deadline to act is short. Ohio taxpayers get 60 days from the Final Determination to petition the Ohio Board of Tax Appeals under R.C. Ch. 5717. We pull your IRS account transcripts, calculate your CSED, file Form 2848 Power of Attorney with the IRS and Ohio TBOR-1 with the Ohio Department of Taxation, and put administrative brakes on collection while the case is built.

Federal tax representation for Toledo 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 — holds occasional trial sessions in Toledo and regular sessions in Cleveland at the Howard M. Metzenbaum U.S. Courthouse, 201 Superior Avenue NE, roughly 130 miles east via the Ohio Turnpike. From our Robertson Boulevard office in Los Angeles, we represent Toledo residents and Ohio-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, and Trust Fund Recovery Penalty defenses under IRC § 6672.

For Ohio state tax matters — the graduated 0% to 3.5% personal income tax under R.C. § 5747.02, the 0.26% Commercial Activity Tax on gross receipts under R.C. Ch. 5751, the 5.75% state sales tax under R.C. § 5739.02 with the Lucas County 1% permissive plus TARTA 0.5% transit tax (combined 7.25% in Toledo), withholding-tax assessments, and contested matters headed to the Ohio Board of Tax Appeals — we file Ohio TBOR-1 Declaration of Tax Representative with the Ohio Department of Taxation and handle the administrative track directly. For Toledo's 2.5% municipal income tax administered by the City of Toledo Income Tax Division under Toledo Municipal Code Ch. 1905, we respond directly to assessment notices and audit requests on letterhead. For formal litigation in the Ohio Board of Tax Appeals (R.C. Ch. 5717) or the Ohio state courts of common pleas, we associate with locally admitted Ohio counsel under a co-counsel arrangement. The federal portion of the engagement, which is usually the larger exposure for Jeep / Stellantis Toledo Assembly UAW and salaried personnel, Owens-Illinois (O-I Glass) corporate executives, Dana Incorporated equity holders, Marathon Petroleum refinery managers, and ProMedica and Mercy Health St. Vincent 1099 physicians, stays with us.

Toledo sits at the western tip of Lake Erie at the mouth of the Maumee River, anchoring one of the most distinctive industrial metros in the Great Lakes region. The Jeep / Stellantis Toledo Assembly Complex, where every Wrangler and Gladiator is built, is the largest single employer in the metro and the global home of the Jeep brand — producing an outsized base of UAW W-2 wage files, salaried-engineering RSU and 401(k) issues, and Schedule C tier-1 supplier work across the broader Detroit-Toledo automotive corridor. Owens-Illinois (O-I Glass), headquartered in Perrysburg just south of Toledo, is one of the largest container-glass manufacturers in the world and drives corporate RSU, ISO, and IRC § 263A inventory-capitalization files. Dana Incorporated, headquartered in Maumee, anchors driveline, sealing, and thermal-management products for the global auto industry with corresponding manufacturing RSU and IRC § 174 research-and-experimentation positions. Marathon Petroleum operates its Toledo refinery (115,000 barrels per day, formerly BP-Husky) along the Maumee River, producing W-2 refining payroll, 1099 contractor turnaround work, and IRC § 263(c) intangible-drilling-cost analogs for downstream capital projects. ProMedica (headquartered downtown), Mercy Health St. Vincent Medical Center, and St. Luke's Hospital generate 1099 physician, biotech, and clinical-trial royalty engagements. The University of Toledo, the UT College of Medicine and Life Sciences, Lourdes University, and Bowling Green State University (BGSU, 25 miles south) produce academic appointments under IRC § 117 tuition-reduction, clergy housing under IRC § 107, post-doctoral fellowship taxation under IRC § 117(c), and IRC § 174 research-credit files. The Toledo Mud Hens (AAA baseball, Detroit Tigers affiliate) and Toledo Walleye (ECHL hockey) carry minor-pro athlete state-sourcing and multi-state filing questions. The Port of Toledo is the largest tonnage port on the U.S. side of Lake Erie and a major Great Lakes / St. Lawrence Seaway shipping hub — producing dockworker wages, customs trust-fund exposure under IRC § 7202, and maritime payroll filing questions. Toledo's Lebanese-American community, one of the oldest Arab-American populations in the United States with roots reaching back to the 1880s and a strong Maronite Catholic identity, plus more recent Bangladeshi and Iraqi-American refugee arrivals, bring FinCEN Form 114 (FBAR), ITIN, and Streamlined Filing Compliance Procedures into nearly every household-finance review. Lucas County's surrounding agricultural belt — corn, soybean, and dairy operations across the Maumee Valley — produces Schedule F, IRC § 175 soil-and-water conservation, IRC § 2032A farmland special-use valuation, and IRC § 1301 farm income-averaging engagements. Finally, Toledo sits five miles south of the Michigan state line and ninety miles east of the Indiana line, making MI-OH cross-border wage allocation under the Michigan-Ohio reciprocity agreement a recurring household issue for Toledo residents commuting north into the Detroit-area auto-supplier base.

Your tax rights as a Toledo taxpayer

Three parallel rights frameworks apply when you owe tax in Toledo. Federal rights come from the Internal Revenue Code and IRS Publication 1, the Taxpayer Bill of Rights. State rights come from Ohio R.C. Title 57 (Taxation) and the Ohio Taxpayers' Bill of Rights at R.C. § 5703.50 through § 5703.56. Municipal rights come from Ohio H.B. 5 (2014) uniform municipal-income-tax provisions codified at R.C. Ch. 718, plus Toledo's local code at Toledo Municipal Code Ch. 1905 as administered by the City of Toledo Income Tax Division. Knowing all three is the difference between a clean resolution and a missed 60-day Ohio Board of Tax Appeals petition deadline that turns into a state tax lien filed with the Lucas County Court of Common Pleas.

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 must deal with us first, not you. Ohio mirrors this through the TBOR-1 Declaration of Tax Representative authorized under R.C. § 5703.05. The City of Toledo Income Tax Division accepts a separate written authorization for Toledo municipal income-tax matters.

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 occasional trial sessions in Toledo and regular sessions in Cleveland at the Howard M. Metzenbaum U.S. Courthouse, 201 Superior Avenue NE, roughly 130 miles east.

Right to Ohio Board of Tax Appeals review

R.C. Ch. 5717 gives you 60 days from a Final Determination of the Tax Commissioner to petition the Ohio Board of Tax Appeals, seated at 30 East Broad Street, 24th Floor, Columbus OH 43215. The BTA is an independent quasi-judicial body with statewide jurisdiction over state and county tax appeals. Decisions are reviewable by the Ohio Supreme Court under R.C. § 5717.04. Tighter than the federal 90-day Tax Court deadline — the 60-day window is jurisdictional.

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 CDP filing halts collection and preserves judicial review in 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. Ohio operates a parallel Offer-in-Compromise program through the Office of the Attorney General under R.C. § 131.02 for accounts certified to AG collection, with hardship standards similar to the federal program. The City of Toledo Income Tax Division accepts municipal-tax payment-plan and hardship submissions on a case-by-case basis under Toledo's local code.

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, especially in audit reconsideration and Innocent Spouse cases under IRC § 6015.

How Victory Tax Lawyers helps Toledo 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 Toledo taxpayers, a federal OIC does not resolve Ohio state liability; we run a parallel Ohio compromise through the Office of the Attorney General under R.C. § 131.02 where the state debt has been certified to AG collection, and we address Toledo municipal balances with the City of Toledo Income Tax Division on a separate 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 Toledo taxpayers between $50,000 and $250,000 in federal debt. Ohio runs its own state Payment Plan program through OH|TAX eServices, and the City of Toledo Income Tax Division accepts Toledo municipal payment plans directly.

Lien discharge, subordination, and withdrawal

When a Notice of Federal Tax Lien blocks a Toledo property sale or refinance, we file Form 14135 (discharge), Form 14134 (subordination), or Form 12277 (withdrawal). NFTLs filed with the Lucas County Recorder encumber title; the IRS procedures under IRC § 6325 set the cure path. Timing must align with the closing on a Old West End, Old Orchard, Ottawa Hills, Perrysburg, Sylvania, or Maumee transaction.

Levy release under IRC § 6343

Wage levies, bank levies, and accounts-receivable levies. 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. Ohio state tax liens follow a parallel track under R.C. § 5747.13 and R.C. Ch. 131, certified to the Ohio Attorney General for collection and recorded in the Lucas County Court of Common Pleas.

Audit defense and U.S. Tax Court litigation

Correspondence audits, office audits, and field examinations — including sensitive issues like Jeep / Stellantis Toledo Assembly UAW Schedule A union-dues deductions and supplemental-unemployment-benefits taxation, Owens-Illinois IRC § 263A inventory-capitalization disputes, Dana Incorporated IRC § 174 research-cost amortization, Marathon Petroleum refining IRC § 263(c) intangible costs, ProMedica and Mercy Health 1099 physician sourcing, cryptocurrency, foreign accounts under FinCEN Form 114 (FBAR) for Lebanese, Bangladeshi, and Iraqi bank accounts, S-corporation reasonable-compensation, and IRC § 83(b) election validation. If the audit closes unfavorably, we petition the U.S. Tax Court within the 90-day IRC § 6213(a) window. Toledo trial sessions are held occasionally; most Northwest Ohio cases are calendared in Cleveland.

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. Ohio penalties under R.C. § 5747.15 and Toledo municipal penalties under Toledo Municipal Code Ch. 1905 follow a separate reasonable-cause analysis.

Twelve types of Toledo tax matters we handle

Federal cases for Toledo residents and businesses, framed against the Ohio Department of Taxation overlay and the Toledo 2.5% municipal income tax where it matters.

Jeep / Stellantis Toledo Assembly UAW and salaried tax work

The Jeep / Stellantis Toledo Assembly Complex is the global home of the Wrangler and Gladiator and the largest single employer in the metro. Hourly UAW members pay 2.5% Toledo municipal income tax on the full Toledo Assembly wage. Schedule A union dues, supplemental-unemployment benefits (SUB), 401(k) profit-sharing, and incentive-bonus timing all generate audit exposure. Salaried engineering and management personnel carry Stellantis N.V. RSU and ESPP positions under IRC § 83 and IRC § 423, with vesting events that arrive under-withheld at the 22% federal supplemental rate against a 37% top bracket. The Toledo-Detroit cross-border population also pulls in MI-OH reciprocity allocation under the Michigan-Ohio reciprocal agreement and R.C. § 5747.05.

Owens-Illinois, Dana, and Marathon Petroleum executive equity

Owens-Illinois (O-I Glass), headquartered in Perrysburg, is one of the largest container-glass manufacturers in the world. Dana Incorporated, headquartered in Maumee, anchors driveline, sealing, and thermal-management products for the global auto industry. Marathon Petroleum's Toledo refinery (115,000 bpd) and ConocoPhillips legacy operations along the Maumee River drive downstream-energy compensation. RSU vesting under IRC § 83 generates ordinary-income W-2 inclusion at vest with a forced supplemental-wage withholding of 22% (or 37% above $1 million in aggregate). ISO disqualifying-disposition events under IRC § 422, AMT bargain-element inclusion under IRC § 56, IRC § 174 research-and-experimentation positions, and IRC § 263A manufacturing inventory-capitalization disputes drive the executive case mix. Add Ohio's 3.5% top bracket plus Toledo's 2.5% municipal income tax, and a $500,000 RSU vesting event arrives in April with six-figure shortfalls against the 37% top bracket.

Trust Fund Recovery Penalty

IRC § 6672 imposes personal liability on officers, partners, and check-signers for unpaid employment-tax withholding. Toledo restaurant, hospitality, construction, trucking, tier-2 auto-supplier, and small-shop manufacturing owners are the most frequent targets. The IRS uses Form 4180 interviews to identify responsible persons. Ohio pursues a parallel responsible-officer claim under R.C. § 5739.33 for unpaid sales-tax trust funds and R.C. § 5747.07 for income-tax withholding.

Toledo 2.5% municipal income tax

Toledo imposes a 2.5% municipal income tax under Toledo Municipal Code Ch. 1905, administered directly by the City of Toledo Income Tax Division at 1 Government Center, Suite 2000 (1 Government Center, Toledo OH 43604). The Toledo rate is equal to Cleveland's, Columbus's, Akron's, and Dayton's 2.5%, and is materially higher than Cincinnati's 1.8%. Toledo-resident taxpayers also owe municipal income tax on income earned outside the city, with a credit for taxes paid to other municipalities under R.C. Ch. 718. Assessment notices carry a 60-day protest window under R.C. Ch. 718; we respond on letterhead with Form 2848 layered on the federal side and a separate written City of Toledo authorization.

Notice of Federal Tax Lien

NFTLs filed with the Lucas County Recorder (or the Wood, Ottawa, Sandusky, Fulton, or Henry County recorders for the surrounding Northwest Ohio counties) encumber title and trigger CDP rights under IRC § 6320. A parallel Ohio state tax lien may be filed by the Ohio Attorney General under R.C. Ch. 131 with the Lucas County Court of Common Pleas, where it operates as a judgment lien against the taxpayer's real and personal property.

IRS bank or wage levy

Bank levies on accounts held at Huntington National Bank, Fifth Third, PNC, KeyBank, Directions Credit Union, Sun Federal Credit Union, Glass City Federal Credit Union, or any Ohio-chartered institution. Wage levies hit Toledo employers within days of CP90 or LT11 issuance — we move on Form 12153 CDP requests and Form 433-F hardship submissions concurrently.

Passport revocation under IRC § 7345

A seriously delinquent tax debt (over $62,000 for 2025, indexed annually) triggers State Department certification and passport hold. Toledo has a substantial Lebanese-American, Bangladeshi, and Iraqi heritage population with regular travel to family abroad through Detroit Metropolitan Wayne County Airport (DTW) one hour north; passport revocation hits these communities hard. We file the IRC § 7345(e) action to reverse the certification.

FBAR and FATCA non-disclosure — Lebanese, Bangladeshi, Iraqi accounts

FinCEN Form 114 for foreign accounts over $10,000 aggregate. Toledo's Lebanese-American community — one of the oldest Arab-American populations in the United States, reaching back to the 1880s with a strong Maronite Catholic identity centered in the historic North End and South Toledo — plus more recent Bangladeshi and Iraqi-American refugee arrivals carry a meaningful share of inherited and continuing accounts at Bank Audi, BLOM Bank, Byblos Bank, BankMed, Bangladesh Bank, BRAC Bank, Sonali Bank, Rafidain Bank, and similar Middle Eastern and South Asian institutions. Streamlined Filing Compliance Procedures are a frequent engagement; willful-failure penalties can reach the greater of $100,000 or 50% of account balances under 31 U.S.C. § 5321(a)(5).

ProMedica, Mercy Health, and UT Health 1099 physician work

ProMedica (headquartered downtown at the Steam Plant on Summit Street), Mercy Health St. Vincent Medical Center, St. Luke's Hospital, and the University of Toledo Health system run a mixed roster of W-2 staff and 1099 independent-contractor physicians. Clinical-trial principal investigators receive royalty and milestone payments tied to medical-device and biotech patents. We work IRC § 1235 patent-sale capital-gain treatment, IRC § 162(a) ordinary-and-necessary deductions for CME, malpractice, and home-office, IRC § 199A qualified-business-income on the 1099 side, and Schedule SE self-employment-tax calculations. The federal-plus-Ohio-plus-Toledo combined effective rate on physician income at the top tier reaches 43% (37% federal + 3.5% Ohio + 2.5% Toledo).

Mud Hens, Walleye, and minor-pro athlete payroll

The Toledo Mud Hens (Triple-A baseball, Detroit Tigers affiliate, Fifth Third Field downtown) and Toledo Walleye (ECHL hockey, Huntington Center) carry rosters of minor-pro athletes paid on W-2 or two-way contracts that frequently move players between major-league and minor-league rosters mid-season — producing multi-state wage allocation under each affected state's duty-day rule. Ohio applies a duty-day analysis under R.C. § 5747.05 for non-resident athletes playing in Toledo, and Toledo's 2.5% municipal income tax applies to visiting-team Toledo-sourced game-day income under R.C. Ch. 718.

Port of Toledo Great Lakes maritime and customs trust funds

The Port of Toledo is the largest tonnage port on the U.S. side of Lake Erie and a major Great Lakes / St. Lawrence Seaway shipping hub. Maritime payroll under the Jones Act and the Foreign Earned Income Exclusion (IRC § 911) for Seaway crew, customs duty trust-fund exposure under IRC § 7202 for freight forwarders, dockworker W-2 reporting, and Schedule C / 1099 contractor work across stevedoring and Great Lakes shipping operators are recurring engagements. Ohio applies the 5.75% state Use Tax under R.C. § 5741.02 to imported equipment used in Ohio operations.

Lucas County agricultural Schedule F

The Maumee Valley corn, soybean, and dairy belt surrounding Toledo produces a recurring Schedule F and farm-tax case mix: IRC § 175 soil-and-water-conservation expense deductions, IRC § 2032A farmland special-use valuation in estates, IRC § 1301 farm-income averaging, dairy-herd depreciation under IRC § 168, and weather-related forced-sale deferral under IRC § 451(g). Crop-insurance proceeds, government farm-program payments, and conservation-easement deductions all generate timing and characterization disputes.

Nine common causes of tax debt for Toledo taxpayers

Patterns we see repeatedly in Toledo-based engagements. None of them are unusual — all of them are resolvable.

1. Jeep / Stellantis profit-sharing and bonus under-withholding

A Jeep / Stellantis Toledo Assembly UAW profit-sharing check or salaried bonus arrives with 22% federal supplemental withholding while the household sits in a 32% or 35% marginal bracket. Add 3.5% Ohio and 2.5% Toledo, and the next April balance often runs $10,000 to $30,000. The CP14 lands in May, the Ohio Notice of Assessment follows within 90 days, and Toledo delinquency notices arrive on top.

2. Corporate RSU and ISO under-withholding

A Stellantis, Owens-Illinois, Dana, or Marathon Petroleum RSU vests; the employer withholds 22% federal supplemental, leaving a six-figure shortfall against the 37% top bracket. Add 3.5% Ohio and 2.5% Toledo, and a $500,000 vesting event arrives in April with $75,000 to $100,000 still owed. The CP14 lands in May, the Ohio Notice of Assessment follows within 90 days.

3. Business closure

When an 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. Ohio pursues a parallel responsible-officer claim under R.C. § 5747.07 for income-tax withholding and R.C. § 5739.33 for trust-fund sales tax.

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. Lucas County divorce filings track the federal record, and unresolved RSU, ISO, or 1099 physician income from a Stellantis, Owens-Illinois, ProMedica, or Mercy Health spouse is a recurring driver.

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. The Ohio Department of Taxation runs a parallel identity-theft unit, and the City of Toledo cross-checks with the Department on suspicious filings.

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. Toledo has a meaningful retail crypto population among UT students and the Stellantis engineering staff.

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. Ohio imposes a parallel late-filing penalty under R.C. § 5747.15. The City of Toledo Income Tax Division pursues unfiled Toledo returns separately under Toledo Municipal Code Ch. 1905.

8. Michigan-Ohio cross-border wage allocation

Toledo residents commuting north into Michigan (the state line sits five miles north of downtown) work under the MI-OH reciprocal agreement: wages earned in Michigan by an Ohio resident are taxed by Ohio only, not Michigan. Filing the wrong state return (or failing to file Michigan Form MI-W4 with the employer to claim the exemption) produces double-withholding and a refund-claim posture that can take 12 to 18 months to unwind through the Michigan Department of Treasury and the Ohio Department of Taxation simultaneously.

9. Lake-effect winter storm casualty losses

Lake-effect snow off Lake Erie produces recurring property damage along the Northwest Ohio corridor. IRC § 165(h) personal-casualty-loss deductions are limited to federally declared disaster areas post-TCJA; without a FEMA declaration, the loss is not deductible. We track the FEMA disaster declarations, the IRS extension-of-deadlines under IRC § 7508A, and the Ohio Department's parallel relief under R.C. § 5747.08(G).

Eight tax liabilities that pull in Toledo taxpayers

Federal authority alongside the Ohio 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. The Ohio mirror is R.C. § 5747.15, with separate late-filing and late-payment exposure on the same balance.

Failure to file Ohio state return

R.C. § 5747.15 imposes a late-filing penalty separate from the federal penalty. The Ohio Department of Taxation may issue a Notice of Assessment under R.C. § 5747.13, triggering a 60-day protest window and, if the protest fails, a Final Determination opening the 60-day Ohio Board of Tax Appeals petition deadline under R.C. Ch. 5717.

Failure to file Toledo municipal return

Toledo Municipal Code Ch. 1905 requires every Toledo resident and non-resident earning Toledo-sourced income to file an annual municipal return with the City of Toledo Income Tax Division. Failure-to-file penalties are calculated under R.C. Ch. 718 uniform municipal-income-tax rules; the city pursues collection through judicial proceedings in the Toledo Municipal Court or the Lucas County Court of Common Pleas.

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.

Ohio sales tax delinquency

R.C. § 5739.02 imposes a 5.75% state sales tax; R.C. § 5739.021 authorizes a Lucas County 1% permissive sales tax plus the TARTA 0.5% transit-authority tax on top, combined 7.25% in Toledo. Personal liability for responsible persons under R.C. § 5739.33 pierces the corporate veil for trust-fund sales tax. The Ohio Department uses the vendor's license revocation as an enforcement lever — pulling a restaurant's license effectively closes the business.

Trust Fund Recovery Penalty

IRC § 6672 imposes 100% personal liability on responsible persons for unpaid trust-fund employment tax. Ohio applies a similar responsible-person rule to withheld state income tax under R.C. § 5747.07 and to sales tax under R.C. § 5739.33.

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.

Ohio Commercial Activity Tax (CAT)

R.C. Ch. 5751 imposes a 0.26% Commercial Activity Tax on gross receipts over the bright-line nexus and exclusion thresholds. Ohio has no traditional corporate income tax; CAT operates as the corporate-level levy on substantial Ohio receipts. CAT registration, quarterly returns, and Annual Minimum Tax obligations apply to every business with Ohio receipts above the threshold — including out-of-state e-commerce sellers shipping into Toledo and Michigan-headquartered auto-supplier operations selling into Stellantis Toledo Assembly.

What resolution can look like

Debt reduced

An accepted IRC § 7122 Offer in Compromise can resolve six-figure balances for cents on the dollar where Reasonable Collection Potential supports the offer. The acceptance rate sits around 33% nationally; 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.

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 Lucas County Recorder.

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 $158,920 IRC § 6159 Installment Agreement Accepted at $25/month, partial-pay
2024 $134,510 Streamlined Installment Agreement Accepted at $25/month
2023 $126,275 Partial-Pay Installment Agreement Accepted at $50/month
2023 $114,830 IRC § 6159 Installment Agreement Accepted at $25/month
2022 $105,640 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, the Ohio Department of Taxation, the City of Toledo Income Tax Division, and the Ohio Board of Tax Appeals.

Why Victory Tax Lawyers for a Toledo federal-tax case

Victory Tax Lawyers is California-Bar-admitted, not Ohio-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 occasional Toledo trial sessions and the regular Cleveland calendar at the Howard M. Metzenbaum U.S. Courthouse, 201 Superior Avenue NE. IRS administrative practice runs on Form 2848 Power of Attorney, which is accepted from any attorney in good standing with any state bar plus an active Centralized Authorization File number. Most of our Toledo clients never need a separately admitted Ohio attorney because the case is, at its core, federal.

For administrative work before the Ohio Department of Taxation — protests, audit responses, Notice of Assessment replies, Final Determination protests, and Payment Plan requests — we file Ohio TBOR-1 Declaration of Tax Representative under R.C. § 5703.05 and handle the matter remotely. For Toledo's 2.5% municipal income tax assessed by the City of Toledo Income Tax Division, we file a written authorization and respond directly on letterhead. When a case must move to the Ohio Board of Tax Appeals (R.C. Ch. 5717) at 30 East Broad Street in Columbus, or to a court of common pleas in Lucas County, we coordinate with locally admitted Ohio counsel under a co-counsel arrangement. The federal portion of the engagement, which is usually the larger exposure for Jeep / Stellantis Toledo Assembly UAW and salaried personnel, Owens-Illinois, Dana, and Marathon Petroleum equity holders, and ProMedica and Mercy Health St. Vincent 1099 physicians, stays with us.

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 an Ohio-licensed firm — we are not. A factually accurate offer of federal tax representation, available to any Toledo 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 to Robertson Boulevard.

Our seven-step process for Toledo 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, TBOR-1, Toledo POA

We file the federal Power of Attorney with the IRS, Ohio TBOR-1 with the Department of Taxation, and a written authorization with the City of Toledo Income Tax Division for Toledo municipal matters.

4

Transcript and CSED analysis

We pull IRS account transcripts via Form 8821, calculate each year's CSED under IRC § 6502, and identify tolling events.

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, or a Board of Tax Appeals petition through local counsel — and handle every IRS, Ohio Department, and City of Toledo 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 Ohio's certified-debt rule

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, and when the taxpayer is outside the United States for six months or more.

Ohio runs a parallel state collection rule. Under R.C. § 5747.13, the Ohio Department of Taxation must issue a Notice of Assessment within four years of the return's due date (no limit for fraud or unfiled returns). Once an Ohio income-tax debt is certified to the Office of the Attorney General under R.C. § 131.02, the AG's Collections Enforcement Section may file a judgment lien with the Lucas County Court of Common Pleas. Ohio income-tax judgment liens are governed by the dormancy and revival rules of R.C. § 2329.07 and may be revived for additional periods. The Toledo municipal income tax, administered by the City of Toledo Income Tax Division under Toledo Municipal Code Ch. 1905 and R.C. Ch. 718, follows a separate collection timeline and is enforced through the Toledo Municipal Court. Many Toledo taxpayers carry a federal CSED, an Ohio AG judgment, and a Toledo municipal balance simultaneously — pull all three records and know all three dates before agreeing to any payment plan or amended return that could restart a clock.

Toledo tax authorities and venues

A working knowledge of the tribunals, agencies, and field offices in metro Toledo is what separates an answered Notice from a wage levy or judgment lien. Below is the working list our firm uses on every Toledo matter.

Internal Revenue Service — Toledo TAC

The federal tax authority, at irs.gov. The Toledo Taxpayer Assistance Center operates at 433 N Summit Street, Toledo OH 43604. Appointments required.

U.S. Tax Court — Toledo and Cleveland trial sessions

The U.S. Tax Court holds occasional trial sessions in Toledo and regular trial sessions in Cleveland at the Howard M. Metzenbaum U.S. Courthouse, 201 Superior Avenue NE, roughly 130 miles east via the Ohio Turnpike. 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).

Ohio Department of Taxation

The state tax authority, at tax.ohio.gov. Headquartered at 4485 Northland Ridge Boulevard, Columbus OH 43229. Administers the 0% to 3.5% graduated personal income tax under R.C. § 5747.02, the 0.26% Commercial Activity Tax on gross receipts under R.C. Ch. 5751, the 5.75% state sales tax under R.C. § 5739.02, the Use Tax under R.C. § 5741.02, and the school-district income tax under R.C. Ch. 5748.

Ohio Board of Tax Appeals

An independent quasi-judicial body with statewide jurisdiction over Ohio Department of Taxation final determinations, county Board of Revision property-tax appeals, and municipal income-tax disputes after exhaustion of local remedies. Seated at 30 East Broad Street, 24th Floor, Columbus OH 43215. 60-day petition deadline from the Final Determination under R.C. Ch. 5717. Decisions are reviewable by the Ohio Supreme Court under R.C. § 5717.04. Victory Tax Lawyers refers Ohio Board of Tax Appeals litigation to locally admitted Ohio counsel; we handle the federal portion and Ohio Department administrative work directly under TBOR-1.

Lucas County Treasurer

The county tax-collection authority for Toledo. Office at 1 Government Center, Suite 500, Toledo OH 43604. Page: co.lucas.oh.us. Administers Lucas County property-tax billing and collection.

Lucas County Auditor

The county assessment authority. Office at 1 Government Center, Suite 600, Toledo OH 43604. Sets the assessed value of Toledo property — the starting point for the county tax bill. Appeals run through the Lucas County Board of Revision, with further review at the Ohio Board of Tax Appeals under R.C. Ch. 5717.

City of Toledo Department of Finance — Income Tax Division

The municipal finance authority at 1 Government Center, Suite 2000, Toledo OH 43604. Toledo's 2.5% municipal income tax under Toledo Municipal Code Ch. 1905 is collected directly by the City of Toledo Income Tax Division — not through the regional Central Collection Agency. Notices carry a 60-day protest window under R.C. Ch. 718.

U.S. District Court — Northern District of Ohio, Toledo 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 (N.D. Ohio, Toledo Division, James M. Ashley and Thomas W. L. Ashley U.S. Courthouse, 1716 Spielbusch Avenue, Toledo OH 43604) or the U.S. Court of Federal Claims in Washington, D.C.

IRS Independent Office of Appeals

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

Taxpayer Advocate Service — Northwest Ohio

An independent organization within the IRS that helps when normal channels stall. The Cleveland TAS office serves taxpayers across Northwest and Northeast Ohio, including Toledo. Page: taxpayeradvocate.irs.gov.

Speak with a tax attorney about your Toledo matter

Free consultation, attorney-client privileged, no obligation. If a Notice of Deficiency, a Final Notice of Intent to Levy, an Ohio Department Final Determination, or a City of Toledo municipal-income-tax 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 — Toledo tax

Does Ohio have a state income tax?

Yes. Ohio operates a graduated personal income tax with rates from 0% to 3.5% under R.C. § 5747.02 — the product of a multi-year phase-down enacted through Am. Sub. H.B. 33 and subsequent budget bills. Ohio has no traditional corporate income tax; instead, corporate-level taxation runs through the 0.26% Commercial Activity Tax on gross receipts under R.C. Ch. 5751. State sales tax is 5.75% under R.C. § 5739.02 with a Lucas County permissive 1% plus the TARTA 0.5% transit tax under R.C. § 5739.021 and 5739.023, producing a combined 7.25% sales-tax rate in Toledo. On top of all that, the City of Toledo imposes a 2.5% municipal income tax under Toledo Municipal Code Ch. 1905, collected by the City of Toledo Income Tax Division at 1 Government Center, Suite 2000. Ohio repealed its estate tax effective January 1, 2013; estate-tax exposure for Ohio residents is federal-only.

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

The U.S. Tax Court holds occasional trial sessions in Toledo. Most Northwest Ohio matters are calendared in Cleveland at the Howard M. Metzenbaum U.S. Courthouse, 201 Superior Avenue NE, roughly 130 miles east via the Ohio Turnpike. A taxpayer in Toledo can request either 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.

What is the Ohio Board of Tax Appeals and how does it work?

The Ohio Board of Tax Appeals is an independent quasi-judicial body with statewide jurisdiction over Ohio Department of Taxation final determinations, county Board of Revision property-tax decisions, and municipal income-tax disputes after exhaustion of local remedies. It is seated at 30 East Broad Street, 24th Floor, Columbus OH 43215. The petition deadline is 60 days from the Tax Commissioner's Final Determination under R.C. Ch. 5717 — tighter than the federal 90-day Tax Court deadline. Decisions are reviewable directly by the Ohio Supreme Court under R.C. § 5717.04. Victory Tax Lawyers refers Ohio Board of Tax Appeals litigation to locally admitted Ohio counsel; we handle the federal portion and Ohio Department administrative work directly under Ohio TBOR-1.

What is Ohio's collection statute of limitations?

R.C. § 5747.13 gives the Ohio Department of Taxation four years from a return's due date to issue a Notice of Assessment (no limit for fraud or unfiled returns). Once an Ohio income-tax debt is certified to the Office of the Attorney General under R.C. § 131.02, the AG's Collections Enforcement Section may file a judgment lien with the county court of common pleas. Ohio income-tax judgment liens are governed by the dormancy and revival rules of R.C. § 2329.07. The federal CSED under IRC § 6502 is 10 years and is not renewable — meaning Ohio judgment liens, if periodically revived, can outlive the federal collection clock. Pulling all records is the first step before agreeing to any payment plan that might restart a clock.

I work at Jeep / Stellantis Toledo Assembly — what tax issues come up?

Hourly UAW members at Toledo Assembly carry a recurring tax issue set: Schedule A union-dues deductions (limited post-TCJA on Schedule A for unreimbursed employee expenses but still allowable as a union member where the dues qualify), supplemental-unemployment-benefits (SUB) treatment under IRC § 3402(o), profit-sharing checks taxed at the 22% federal supplemental rate that frequently under-withholds the 24% or 32% marginal household bracket, 401(k) loan default and early-distribution exposure under IRC § 72(t), and the 2.5% Toledo municipal income tax applied to the full Toledo Assembly wage. Salaried engineering and management personnel carry Stellantis N.V. RSU and ESPP positions with vesting events that arrive under-withheld at the 22% federal supplemental rate against a 37% top bracket. Schedule C tier-1 supplier contractors face self-employment tax, IRC § 199A qualified-business-income, and IRC § 6672 trust-fund exposure where they run their own payroll.

I commute from Toledo to a job in Michigan — how does that work?

Ohio and Michigan have a reciprocal income-tax agreement: wages earned in Michigan by an Ohio resident are taxed only by Ohio, and vice versa. To make the reciprocity work, the Ohio-resident employee must file Michigan Form MI-W4 with the Michigan employer to claim exemption from Michigan withholding. Without it, the employer withholds Michigan tax, the employee pays Ohio tax on the same wages, and recovering the Michigan over-withholding requires filing Michigan Form 1040 as a non-resident and claiming a refund — a process that can take 12 to 18 months. Toledo-resident commuters working in the Detroit metropolitan area auto-supplier base see this often. Note: reciprocity applies only to wage and salary income, not to business or partnership income, which remains taxable in the state where the business operates.

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

Ohio handles state-tax compromises differently from many states. Once an Ohio income-tax debt is certified to the Office of the Attorney General under R.C. § 131.02, the AG's Collections Enforcement Section may consider a compromise offer based on doubt as to collectibility or financial hardship. Hardship standards mirror the federal framework, but documentation requirements are tighter and the AG generally insists on full disclosure of household finances and asset values. We typically run an Ohio AG compromise in parallel with the federal Offer where both debts are real. The City of Toledo Income Tax Division, which collects the Toledo 2.5% municipal income tax, accepts payment-plan and hardship submissions on a case-by-case basis under Toledo's local code.

How does Toledo's 2.5% municipal income tax compare to other Ohio cities?

Toledo's 2.5% rate is equal to Cleveland's, Columbus's, Akron's, and Dayton's, and is materially higher than Cincinnati's 1.8%. The structure is governed by the uniform municipal income tax provisions in R.C. Ch. 718 (Ohio H.B. 5 of 2014) and Toledo's local code at Toledo Municipal Code Ch. 1905. Toledo-resident taxpayers also owe municipal income tax on income earned outside the city, with a credit for taxes paid to other municipalities. Unlike the Central Collection Agency cooperative that administers Cleveland's tax along with dozens of other Northeast Ohio cities, Toledo runs its own Income Tax Division within the City of Toledo Department of Finance at 1 Government Center, Suite 2000. Assessment notices carry a 60-day protest window.

I have a Lebanese, Bangladeshi, or Iraqi bank account — do I have to report it?

Yes, if the aggregate value of all foreign financial accounts you own or have signature authority over exceeded $10,000 at any point during the calendar year. FinCEN Form 114 (FBAR) is due April 15 with an automatic extension to October 15. Non-willful failure to file carries up to a $10,000 civil penalty per violation; willful failure can reach the greater of $100,000 or 50% of account balances under 31 U.S.C. § 5321(a)(5). The IRS Streamlined Filing Compliance Procedures — both Domestic and Foreign — offer a path to bring accounts at Bank Audi, BLOM Bank, Byblos Bank, BankMed, Bangladesh Bank, BRAC Bank, Sonali Bank, Rafidain Bank, and similar Middle Eastern and South Asian institutions into compliance with substantially reduced penalty exposure. Toledo's historic Lebanese-American community — one of the oldest Arab-American populations in the United States, with roots reaching back to the 1880s and a strong Maronite Catholic identity — plus more recent Bangladeshi and Iraqi-American refugee arrivals make this a frequent engagement, particularly where inherited accounts have gone unreported for years.

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

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 Toledo and Cleveland. For Ohio Department of Taxation administrative work, we file Ohio TBOR-1 Declaration of Tax Representative and handle the matter remotely. For the Toledo 2.5% municipal income tax administered by the City of Toledo Income Tax Division, we file a written authorization with the agency. For formal litigation in the Ohio Board of Tax Appeals or an Ohio state court, we co-counsel with locally admitted Ohio attorneys. Most engagements — audit defense, OIC, IA, levy release, 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). Ohio follows a parallel filing-compliance posture; the Department may issue a Notice of Assessment under R.C. § 5747.13 when a taxpayer fails to file, and the City of Toledo pursues unfiled Toledo returns separately.

Can the IRS or the Ohio Department levy my Toledo 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 Huntington National Bank, Fifth Third, PNC, KeyBank, Directions Credit Union, Sun Federal Credit Union, Glass City Federal Credit Union, or any Ohio-chartered institution and serve wage levies on Toledo 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). The Ohio Department, after certification to the Attorney General under R.C. § 131.02, may file a judgment lien and pursue garnishments through the Lucas County Court of Common Pleas.

I am a ProMedica or Mercy Health St. Vincent 1099 physician — what should I worry about?

Four things sit on top of every ProMedica, Mercy Health St. Vincent, St. Luke's, or UT Health 1099 physician file we open. First, self-employment tax under IRC § 1401 stacks 15.3% on the first $168,600 of net earnings (2024 wage base, indexed annually) and 2.9% Medicare with no cap on top — before federal income tax even applies. Second, clinical-trial royalty income flowing from medical-device or biotech patents may qualify for IRC § 1235 capital-gain treatment if structured as a transfer of substantially all rights, but the IRS scrutinizes the contract closely. Third, IRC § 162(a) ordinary-and-necessary deductions for CME, professional liability insurance, board-certification fees, white-coat and scrubs costs, and a home-office deduction under IRC § 280A all require contemporaneous records. Fourth, IRC § 199A qualified-business-income deduction phases out for specified-service-trade-or-business (medical practice) at the top of the income range, but planning opportunities remain. The federal-plus-Ohio-plus-Toledo combined effective rate on top-tier physician income reaches 43%.

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. An Ohio AG compromise under R.C. § 131.02 typically runs four to nine months on a parallel track.

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 / OIC submission that triggers the IRC § 6331(k) collection bar. We move on those concurrently when a levy is in place. Ohio state collection follows a similar pattern: a TBOR-1 routes state contact, and a pending Ohio AG compromise or Payment Plan request pauses enforcement. The City of Toledo halts municipal collection once a payment plan or written protest is on file.

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 Ohio statute citation references the Ohio Revised Code maintained by the Ohio General Assembly. 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 Ohio Department of Taxation, the City of Toledo Income Tax Division, the U.S. Tax Court, the Ohio Board of Tax Appeals, 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 Ohio; where an Ohio state-court appearance or Ohio Board of Tax Appeals litigation is required, the firm associates with locally admitted 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.

Related practice areas

Offer in Compromise

IRC § 7122 settlements

Installment Agreement

IRC § 6159 payment plans

Tax Lien Help

NFTL release and discharge

Tax Levy Defense

IRC § 6343 release

Audit Representation

IRS examinations

Penalty Abatement

IRC § 6651 relief

Back Taxes

Unfiled-return resolution

Ohio state hub

Statewide OH practice

See other areas

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Authorities cited on this page

  • 26 U.S.C. § 7122 — Federal Offer in Compromise
  • 26 U.S.C. § 6159 — Installment Agreements
  • 26 U.S.C. § 6321 — Federal Tax Lien
  • 26 U.S.C. § 6325 — Lien Release and Discharge
  • 26 U.S.C. § 6331 — Levy and Distraint
  • 26 U.S.C. § 6343 — Release of Levy
  • 26 U.S.C. § 6502 — Collection Statute Expiration
  • 26 U.S.C. § 6213 — Tax Court Petition Window
  • 26 U.S.C. § 6320 — CDP for Liens
  • 26 U.S.C. § 6330 — CDP for Levies
  • 26 U.S.C. § 6651 — Failure-to-File and Failure-to-Pay
  • 26 U.S.C. § 6672 — Trust Fund Recovery Penalty
  • 26 U.S.C. § 6015 — Innocent Spouse Relief
  • 26 U.S.C. § 7345 — Passport Revocation
  • 26 U.S.C. § 83 — Property Transferred in Connection with Performance of Services (RSU vesting)
  • 26 U.S.C. § 422 — Incentive Stock Options
  • 26 U.S.C. § 423 — Employee Stock Purchase Plans
  • 26 U.S.C. § 1235 — Patent Sale Capital-Gain Treatment
  • 26 U.S.C. § 199A — Qualified Business Income Deduction
  • 26 U.S.C. § 174 — Research and Experimental Expenditures
  • 26 U.S.C. § 263A — Manufacturing UNICAP Rules
  • 26 U.S.C. § 175 — Soil and Water Conservation Expenditures
  • 26 U.S.C. § 1301 — Farm Income Averaging
  • 26 U.S.C. § 2032A — Farmland Special-Use Valuation
  • 26 U.S.C. § 165 — Casualty Loss Deduction
  • 26 U.S.C. § 7202 — Willful Failure to Collect or Pay Over Tax
  • 31 U.S.C. § 5321 — FBAR civil penalties
  • R.C. § 5747.02 — Ohio graduated personal income tax (0% to 3.5%)
  • R.C. § 5747.05 — Ohio non-resident athlete duty-day allocation
  • R.C. § 5747.07 — Ohio withholding-tax responsible-officer liability
  • R.C. § 5747.08 — Ohio resident return and federal disaster relief
  • R.C. § 5747.10 — Ohio federal-change reporting
  • R.C. § 5747.13 — Ohio Notice of Assessment and assessment statute of limitations
  • R.C. § 5747.15 — Ohio late-filing and late-payment penalty
  • R.C. Ch. 5751 — Ohio Commercial Activity Tax (0.26% on gross receipts)
  • R.C. § 5739.02 — Ohio state sales tax (5.75%)
  • R.C. § 5739.021 — Lucas County permissive sales tax (1%)
  • R.C. § 5739.023 — TARTA transit-authority sales tax (0.5%)
  • R.C. § 5739.33 — Ohio sales-tax responsible-person liability
  • R.C. § 5741.02 — Ohio Use Tax
  • R.C. § 5703.05 — Ohio Tax Commissioner powers and TBOR-1 authority
  • R.C. § 5703.50 to 5703.56 — Ohio Taxpayers' Bill of Rights
  • R.C. Ch. 5717 — Ohio Board of Tax Appeals (60-day petition window)
  • R.C. § 5717.04 — Ohio Supreme Court review of Board of Tax Appeals decisions
  • R.C. Ch. 5748 — Ohio school-district income tax
  • R.C. Ch. 718 — Ohio uniform municipal income tax (H.B. 5 of 2014)
  • R.C. § 131.02 — Certification of state debts to the Ohio Attorney General
  • R.C. § 2329.07 — Ohio judgment-lien dormancy and revival
  • Toledo Municipal Code Ch. 1905 — Toledo 2.5% municipal income tax