Tax Attorney in Trenton, NJ

Federal IRS representation for Trenton residents, New Jersey state employees, the Princeton University academic and 1099 community, Mercer County businesses, and PA-NJ Delaware River commuters — audits, back taxes, liens, levies, payroll-tax disputes, §117(c) post-doctoral fellowship exposure, §107 parsonage allowance reviews, and U.S. Tax Court litigation at the Philadelphia trial location (Byrne U.S. Courthouse, 65 miles southwest) or the Newark trial location (970 Broad Street, 55 miles northeast). We also coordinate New Jersey Division of Taxation matters — whose headquarters sits at 3 John Fitch Way, four blocks from the State House — under Form M-5008-R Power of Attorney.

Reviewed by Parham Khorsandi, Esq. — California Bar #266658. Last reviewed: May 26, 2026.

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

Trenton is the capital of New Jersey, and the two agencies that decide most state tax cases sit inside the city limits. The New Jersey Division of Taxation is headquartered at 3 John Fitch Way, four blocks from the State Capitol, and the New Jersey Tax Court — the state's specialized tax tribunal — sits one block away at the Richard J. Hughes Justice Complex, 25 Market Street, 7th Floor. New Jersey's graduated personal income tax runs from 1.4% to 10.75% under N.J.S.A. 54A:2-1, with the 10.75% top bracket the third-highest state income-tax rate in the country after California and Hawaii. The Corporation Business Tax under N.J.S.A. 54:10A-5 sits at 11.5%. The state sales tax is 6.625% under N.J.S.A. 54:32B-3.

Trenton also sits on the Pennsylvania border. The Delaware River is the western city limit and the Lower Trenton Bridge (with the lit "Trenton Makes The World Takes" sign) connects the city directly to Morrisville, Pennsylvania one mile west. New Jersey and Pennsylvania have maintained a reciprocal personal-income-tax agreement since 1977: a New Jersey resident working in Pennsylvania pays no Pennsylvania personal income tax (only New Jersey), and a Pennsylvania resident working in New Jersey pays no New Jersey personal income tax (only Pennsylvania). This is unique on the New Jersey border — no such agreement exists with New York, and the cross-river math for a Trenton or Mercer County resident commuting to Philadelphia or Bucks County is far simpler than for a Jersey City resident commuting to Manhattan. The trade-off: the rule that the home state's PIT alone applies often surprises Pennsylvania residents who relocate to a New Jersey job and discover at filing time that no New Jersey withholding was taken.

If you have received an IRS CP504, LT11, or Statutory Notice of Deficiency, or if the New Jersey Division of Taxation has issued a Notice of Deficiency or a Final Determination, the deadline to act is short. We pull your IRS account transcripts, calculate your CSED, file Form 2848 Power of Attorney with the IRS and Form M-5008-R with the New Jersey Division of Taxation, and put administrative brakes on collection while the case is built.

Federal tax representation for Trenton 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 regular trial sessions at the Philadelphia location (James A. Byrne U.S. Courthouse, 601 Market Street, about 65 miles southwest of Trenton on I-95) and at the Newark location (970 Broad Street, 55 miles northeast on the New Jersey Turnpike). From our Robertson Boulevard office in Los Angeles, we represent Trenton residents, state-government employees, Princeton-area academics, Mercer County businesses, and PA-NJ Delaware River commuters 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 New Jersey state tax matters — the 1.4% to 10.75% graduated personal income tax under N.J.S.A. 54A:2-1, the 11.5% Corporation Business Tax under N.J.S.A. 54:10A-5, the 6.625% state sales tax under N.J.S.A. 54:32B-3, withholding-tax assessments under N.J.S.A. 54A:7-1, the New Jersey Business Alternative Income Tax (BAIT) elective pass-through entity tax under N.J.S.A. 54A:12-1 et seq., and the New Jersey inheritance tax under N.J.S.A. 54:34-1 et seq. — we file Form M-5008-R Appointment of Taxpayer Representative with the Division of Taxation and handle the administrative track directly. The Division's headquarters at 3 John Fitch Way puts every state-tax decision, hearing officer, and Closing Agreement reviewer within walking distance of the Tax Court — an unusual concentration that makes Trenton, more than any other New Jersey city, the place where state tax matters get decided. For formal litigation in the New Jersey Tax Court at the Hughes Justice Complex or in the New Jersey Superior Court Appellate Division, we refer to locally admitted New Jersey counsel under a co-counsel arrangement.

Trenton's working population breaks down differently than any other New Jersey city. State government is the single largest employer concentration in the region: the Executive Branch and Treasury Department around 225 West State Street, the State Legislature at 125 West State Street, the Attorney General's office, the Department of Law and Public Safety, the Department of Transportation, and the Department of Human Services run a payroll that produces tens of thousands of W-2 employees plus a steady stream of 1099 contractors, legislative session per-diem recipients, and consulting engagements that pull in tax exposure rarely seen in cities without a capital-city footprint. Ten miles north, Princeton University and the Institute for Advanced Study run an academic workforce that adds §117(c) post-doctoral fellowship taxation, §107 clergy parsonage allowances at Princeton Theological Seminary, §174 research-expenditure questions, name-image-and-likeness (NIL) §61 inclusions for Princeton athletes, and §1202 Qualified Small Business Stock issues for the steady stream of Princeton spinout founders. The medical layer — Capital Health, St. Francis Medical Center, Robert Wood Johnson University Hospital Hamilton — produces a 1099 attending-physician book. Trenton's Indian, Filipino, African-American, Hispanic-American, and Liberian populations carry meaningful FBAR exposure on overseas accounts; the Hamilton and Lawrence Township Indian community in particular carries some of the highest per-capita FinCEN Form 114 exposure outside of the Edison-Iselin corridor further north.

Your tax rights as a Trenton 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 come from the New Jersey Taxpayer Bill of Rights at N.J.S.A. 54:1-2.1 and the procedural rules at N.J.S.A. 54:49-1 et seq. Knowing both is the difference between a clean resolution and a missed 90-day New Jersey Tax Court appeal window that ends in a Certificate of Debt docketed against your Hamilton, Ewing, Lawrence, or West Windsor 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 must deal with us first, not you. New Jersey mirrors this through Form M-5008-R Appointment of Taxpayer Representative, accepted by the Division of Taxation for all administrative tax matters at the John Fitch Way headquarters.

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 U.S. Tax Court holds regular trial sessions at the Philadelphia location (James A. Byrne U.S. Courthouse, 601 Market Street, 65 miles southwest of Trenton) and at the Newark location (970 Broad Street, 55 miles northeast).

Right to New Jersey Tax Court review

N.J.S.A. 54:51A-14 gives you 90 days from a Final Determination of the Director of the Division of Taxation to file a complaint in the New Jersey Tax Court — the state's specialized tax tribunal seated right here in Trenton at the Richard J. Hughes Justice Complex, 25 Market Street, 7th Floor. Trenton-resident filers do not need to travel for hearings: the Tax Court holds proceedings inside the city. The 90-day window aligns with the federal Tax Court deadline. Missing it forfeits the right to pre-payment judicial review.

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.

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. New Jersey runs a parallel Closing Agreement program under N.J.S.A. 54:53-1 with similar hardship and insolvency standards, including the Division's Closing Agreement Application for individual and business tax liabilities. Both programs require all returns filed before consideration.

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 Trenton 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 Trenton taxpayers, a federal OIC does not resolve New Jersey state liability; we run a parallel Closing Agreement Application with the Division of Taxation under N.J.S.A. 54:53-1, hand-delivered when warranted to the John Fitch Way headquarters four blocks from the State House.

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 — the most under-used resolution path for Trenton taxpayers carrying between $50,000 and $250,000 in federal debt, particularly state-government mid-career employees with deferred-compensation distributions, Princeton-area private-practice physicians, and Mercer County contractors with seasonal Schedule C income.

Lien discharge, subordination, and withdrawal

When a Notice of Federal Tax Lien blocks a Hamilton, Lawrence, Ewing, West Windsor, or Hopewell home sale or refinance, we file Form 14135 (discharge), Form 14134 (subordination), or Form 12277 (withdrawal). NFTLs filed with the Mercer County Clerk encumber title on residential and commercial property throughout the county; the IRS procedures under IRC § 6325 set the cure path. Timing must align with the closing.

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. New Jersey state tax liens follow a parallel track: the Division dockets a Certificate of Debt under N.J.S.A. 54:49-12 with the Superior Court Clerk — whose office is two blocks from the Division's John Fitch Way headquarters — functioning as a state-court judgment lien on real property in the county where docketed.

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, §117(c) post-doctoral fellowship classification at Princeton and the Institute for Advanced Study, §107 parsonage allowance review for Princeton Theological Seminary clergy, §1202 Qualified Small Business Stock holding-period and gross-asset thresholds for Princeton spinouts, and PA-NJ reciprocity allocation disputes. If the audit closes unfavorably, we petition the U.S. Tax Court within the 90-day IRC § 6213(a) window. Trial sessions are held at Philadelphia (601 Market Street) or Newark (970 Broad Street).

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. New Jersey penalties under N.J.S.A. 54:49-4 and N.J.S.A. 54:49-6 follow a separate reasonable-cause analysis applied by the Division and reviewable by the New Jersey Tax Court in Trenton.

Twelve types of Trenton tax matters we handle

Federal cases for Trenton residents, state-government employees, Princeton-area academics, and Mercer County businesses, framed against the New Jersey Division of Taxation and the PA-NJ reciprocity rule where they matter.

New Jersey state-employee underwithholding and deferred-comp distributions

State of New Jersey W-2 employees in the Executive Branch, the Legislature, the Treasury, the Attorney General's office, and the Department of Transportation receive standard payroll withholding that often falls short when a year-end deferred-compensation distribution under the State of New Jersey Deferred Compensation Plan, a Public Employees' Retirement System (PERS) buyback, or a longevity-pay bump pushes the employee into a higher bracket. Lump-sum vacation payouts on retirement frequently produce a five-figure April balance due.

Legislative session per-diem and 1099 consulting income

Legislators, legislative staff, agency-board members, and the steady consulting industry that serves Trenton state government generate 1099 income that the recipient sometimes treats as informal pocket money. The IRS Form 1099-MISC matching program catches it. We file Schedule C with proper §162 ordinary-and-necessary deductions, §274(d) travel substantiation for the legislative session, and home-office §280A allocation where applicable.

Princeton University and Institute for Advanced Study post-doctoral §117(c) issues

Post-doctoral fellowship stipends at Princeton University (10 miles north of Trenton), the Institute for Advanced Study, and Princeton Theological Seminary are routinely paid as "fellowship" amounts that the recipient assumes are tax-free under IRC § 117. IRC § 117(c) disagrees: amounts paid as compensation for past, present, or future services are taxable wages, even where the institution calls the payment a fellowship. The reclassification produces back-tax assessments running multiple years for post-docs who relied on the original characterization.

§107 parsonage allowance for Princeton Theological Seminary and Trenton-area clergy

IRC § 107 excludes from gross income a "minister of the gospel's" parsonage allowance, capped at the fair rental value of the housing furnished or, for cash allowances, at actual housing expenditures. Princeton Theological Seminary clergy, Trenton-area pastors, and the Diocese of Trenton (Roman Catholic) priests routinely run §107 questions on the cash-allowance designation timing, the housing-expense documentation, and the self-employment tax under IRC § 1402 that still applies to the §107-excluded amount.

§1202 Qualified Small Business Stock for Princeton spinout founders

Princeton University and the Institute for Advanced Study produce a steady stream of academic-spinout C-corporations whose founders and early employees hold stock that may qualify for IRC § 1202 gain exclusion — up to $10M or 10x basis on qualified small business stock held more than five years and acquired at original issuance from a C-corp meeting the $50M gross-asset test. The five-year holding period, original-issuance requirement, and active-business-asset tests trip founders who exit too early or restructure through a holding entity without preserving the §1202 status.

PA-NJ reciprocity wage allocation and withholding mismatches

The 1977 Pennsylvania-New Jersey Reciprocal Personal Income Tax Agreement (continued in force) provides that a New Jersey resident working in Pennsylvania pays no Pennsylvania PIT (only New Jersey), and a Pennsylvania resident working in New Jersey pays no New Jersey PIT (only Pennsylvania). The employee files Form NJ-165 (PA resident) or Form REV-419 (NJ resident working in PA) with the employer. When the form is not filed or is filed late, double withholding occurs and refund claims must be made with the wrong-state Department of Revenue. We coordinate the cleanup and recover refunds on both sides of the river.

FBAR and FATCA non-disclosure

FinCEN Form 114 for foreign accounts aggregating over $10,000. Trenton's Indian (Hamilton and Lawrence Township), Filipino, African-American, Liberian, and Hispanic-American populations carry steady FBAR exposure on overseas accounts inherited from family, used for property in the country of origin, or maintained for cross-border business. The IRS Streamlined Filing Compliance Procedures are a routine engagement. IRC § 6038D Form 8938 reporting layers on top for higher account thresholds.

Trust Fund Recovery Penalty

IRC § 6672 imposes personal liability on officers, partners, and check-signers for unpaid employment-tax withholding. Trenton restaurant, hospitality, retail, construction, and small-business owners are the most common targets, including the lobbying and consulting shops that serve state government. The IRS uses Form 4180 interviews to identify responsible persons; New Jersey applies a parallel responsible-person rule under N.J.S.A. 54:50-8 to unpaid state withholding and sales tax.

New Jersey inheritance tax (Class A / C / D)

New Jersey repealed its estate tax effective January 1, 2018, but retained the inheritance tax under N.J.S.A. 54:34-1 et seq. — making New Jersey, alongside Maryland, one of only two states that carry this kind of relationship-based state-level death-transfer tax. Rates are graduated by the relationship of the beneficiary to the decedent: Class A (spouse, parent, child, grandchild, other lineal descendants) is fully exempt; Class C (siblings, sons-in-law, daughters-in-law) pays 11% on amounts to $1.075 million and 13% to 14% above; Class D (everyone else — nieces, nephews, cousins, friends, business partners) pays 15% to 16%. Form IT-R filings can stack with federal Form 706 estate tax when the gross estate exceeds the federal exemption.

Notice of Federal Tax Lien on Mercer County property

NFTLs filed with the Mercer County Clerk encumber title and trigger CDP rights under IRC § 6320. A parallel New Jersey Certificate of Debt under N.J.S.A. 54:49-12 may be docketed with the Superior Court Clerk in Trenton. Hamilton, Ewing, Lawrence, West Windsor, Hopewell, Pennington, Princeton Junction, and downtown Trenton property refinances and sales stall when an NFTL or Certificate of Debt hits the title search.

IRS bank or wage levy

Bank levies on accounts held at PNC Bank, Bank of America, TD Bank, Wells Fargo, Valley National, Provident Bank, First Bank, or any New Jersey-chartered institution. Wage levies hit Trenton employers within days of CP90 or LT11 issuance — including the State of New Jersey payroll, Capital Health, Robert Wood Johnson University Hospital Hamilton, St. Francis Medical Center, Princeton University, the Institute for Advanced Study, and the Mercer County government workforce.

Schedule F farm income for South Jersey agriculture

Mercer County's southern townships and the broader South Jersey agricultural belt produce tomato, corn, soybean, and nursery-stock operations that file Schedule F. Income averaging under IRC § 1301, depreciation under IRC § 168(k) on equipment, the deduction for soil and water conservation expenditures under IRC § 175, and the family-farm exemption from the New Jersey inheritance tax under N.J.S.A. 54:34-2 are routine planning and audit issues.

Nine common causes of tax debt for Trenton taxpayers

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

1. State-employee retirement lump-sum payout

A New Jersey state employee retires with accumulated vacation, sick-time payout, and a Deferred Compensation Plan distribution all hitting the same year. Default withholding on the lump-sum portion at 22% federal supplemental, combined with 10.75% New Jersey at the top bracket, produces a five-figure April balance due before any deferred-comp basis recovery is even accounted for.

2. PA-NJ reciprocity form missed at hire

A Pennsylvania resident starting a job in Trenton fails to file Form NJ-165 with the employer, so New Jersey withholding is taken from every paycheck. The employee files a Pennsylvania resident return claiming all the income, plus a non-resident New Jersey return to recover the wrongly-withheld New Jersey tax. The mechanics work, but the cash-flow gap and refund-claim filing window catch the unprepared.

3. Self-employment underpayment

Capital Health, Robert Wood Johnson, and St. Francis Medical Center attending physicians with private 1099 practices, Princeton-area finance and tech consultants, real-estate agents, and tradespeople 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.

4. 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. Common in Trenton's restaurant, retail, lobbying, and small-construction sectors.

5. 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. New Jersey applies an equitable-distribution analysis on the underlying matrimonial debt, not pure community property.

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.

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. New Jersey mirrors the federal three-year refund bar under N.J.S.A. 54A:9-8.

8. Real-estate sale without estimated tax

A Princeton, West Windsor, or Hopewell home sale generating substantial capital gain on a long-held property, with no Form 1040-ES payment, produces a tax bill the next April. New Jersey's separate Realty Transfer Fee under N.J.S.A. 46:15-7 (the "mansion tax" portion at 1% on residential sales over $1 million) is collected at closing and is not a federal deduction.

9. §117(c) post-doc reclassification

A Princeton or Institute for Advanced Study post-doctoral fellow treats the stipend as tax-free under IRC § 117. The IRS reclassifies under §117(c) as compensation for services. Three or four years of back tax and accuracy-related penalties under IRC § 6662 land together when the prior-year returns are audited.

Eight tax liabilities that pull in Trenton taxpayers

Federal authority alongside the New Jersey 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 New Jersey mirror is N.J.S.A. 54:49-4, imposing a 5% per month late-filing penalty on unpaid New Jersey tax, capped at 25%.

Failure to file New Jersey state return

N.J.S.A. 54:49-4 imposes a 5% per month penalty on the unpaid New Jersey tax for failure to file, capped at 25%, with interest under N.J.S.A. 54:48-2 at the prime rate plus three percentage points. The Division of Taxation at 3 John Fitch Way may issue a Notice of Deficiency under N.J.S.A. 54:49-6, triggering protest rights and ultimately the 90-day New Jersey Tax Court appeal window under N.J.S.A. 54:51A-14.

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.

New Jersey sales-tax delinquency

N.J.S.A. 54:32B-3 sets the 6.625% state sales tax. The Urban Enterprise Zone reduced rate (3.3125%) applies inside designated UEZs — portions of Trenton are inside a designated UEZ, producing a reduced-rate sales tax inside the zone boundary. N.J.S.A. 54:50-8 imposes personal liability on responsible persons for unpaid trust-fund sales tax.

Trust Fund Recovery Penalty

IRC § 6672 imposes 100% personal liability on responsible persons for unpaid trust-fund employment tax. New Jersey applies a parallel responsible-person rule under N.J.S.A. 54:50-8 to unpaid state withholding and sales tax.

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.

New Jersey inheritance tax

N.J.S.A. 54:34-1 et seq. imposes a graduated inheritance tax by beneficiary class on transfers from a New Jersey decedent: Class A (spouse, lineal ascendant or descendant) is exempt; Class C (siblings and spouses-of-children) pays 11% to 13% to 14%; Class D (everyone else) pays 15% to 16%. New Jersey repealed its estate tax effective January 1, 2018 (N.J.S.A. 54:38-1 amendment), so the inheritance tax is now the sole state-level death-transfer levy. Form IT-R is filed with the Inheritance Tax Branch at the Division of Taxation headquarters in Trenton.

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.

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 Mercer 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 New Jersey Division of Taxation.

Why Victory Tax Lawyers for a Trenton federal-tax case

Victory Tax Lawyers is California-Bar-admitted, not New Jersey-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 the Philadelphia trial location (James A. Byrne U.S. Courthouse, 601 Market Street, 65 miles southwest of Trenton) and the Newark trial location at 970 Broad Street, 55 miles northeast. 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 Trenton clients never need a separately admitted New Jersey attorney because the case is, at its core, federal.

For administrative work before the New Jersey Division of Taxation — protests, audit responses, Closing Agreement Applications under N.J.S.A. 54:53-1, and installment-payment requests — we file Form M-5008-R Appointment of Taxpayer Representative and handle the matter remotely. Trenton is the easiest New Jersey city for this work: the Division of Taxation headquarters at 3 John Fitch Way is the agency, full stop — no regional service office routing, no transfer between local and central staff. When a case must move to the New Jersey Tax Court at the Hughes Justice Complex one block from the Division's office, or appeal further to the Superior Court Appellate Division, we coordinate with locally admitted New Jersey counsel under a co-counsel arrangement. The federal portion of the engagement — which is usually the bigger exposure given New Jersey's 10.75% top personal income tax bracket plus the federal §117(c), §107, §1202, and FBAR layers on top — 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 a New Jersey-licensed firm — we are not. A factually accurate offer of federal tax representation, available to any Trenton 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, and we never have to drive across the country to your Hamilton, Ewing, Lawrence, West Windsor, or downtown Trenton home.

Our seven-step process for Trenton clients

Free consultation

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

Engagement letter

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

Form 2848 and M-5008-R

We file the federal Power of Attorney with the IRS and Form M-5008-R with the New Jersey Division of Taxation at 3 John Fitch Way, register on the CAF system, and step in as the contact of record.

Transcript and CSED analysis

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

Strategy memo

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

Filing and negotiation

We file the operative document — Form 656, Form 433-A(OIC), Form 9423, Form 12153, or a New Jersey Tax Court complaint through local counsel — and handle every IRS and Division of Taxation contact.

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 New Jersey's assessment statute

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.

New Jersey runs a parallel state collection rule. N.J.S.A. 54A:9-4 gives the Division of Taxation three years from the return due date to assess additional Gross Income Tax (and most other taxes), extended to six years for omitted income exceeding 25% of gross income reported, with no limit for fraud or unfiled returns. Once a Certificate of Debt is docketed with the Superior Court under N.J.S.A. 54:49-12, it functions as a judgment lien on real property for 20 years and may be renewed. Many Trenton taxpayers carry a federal CSED that will run out before the New Jersey state collection rights expire, or vice versa. Pull both records and know both dates before agreeing to any payment plan or amended return that could restart a clock.

Trenton tax authorities and venues

A working knowledge of the tribunals, agencies, and field offices serving Trenton is what separates an answered Notice from a wage levy. Below is the working list our firm uses on every Mercer County matter — with the additional advantage that almost every state-tax decision-maker in New Jersey sits within walking distance of the Trenton State House.

Internal Revenue Service — Trenton TAC

The federal tax authority, at irs.gov. The Trenton Taxpayer Assistance Center operates at Capital Place 1, 50 West State Street, Suite 1300, Trenton NJ 08608. The Edison TAC at 100 Dey Place is the larger backup office 25 miles north. Appointments required.

U.S. Tax Court — Philadelphia and Newark trial sessions

The U.S. Tax Court holds regular trial sessions at the Philadelphia location (James A. Byrne U.S. Courthouse, 601 Market Street, Philadelphia PA 19106, about 65 miles southwest of Trenton on I-95) and at the Newark location (970 Broad Street, Newark NJ 07102, about 55 miles northeast on the New Jersey Turnpike). A Trenton taxpayer may 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.

New Jersey Division of Taxation — headquarters

The state tax authority, at nj.gov/treasury/taxation. Headquartered at 3 John Fitch Way, Trenton NJ 08611 — four blocks from the State House and one block from the New Jersey Tax Court. This is the single agency for the entire state: there is no regional office in Trenton because the agency itself is in Trenton. Administers the 1.4% to 10.75% graduated Gross Income Tax under N.J.S.A. 54A:2-1, the 11.5% Corporation Business Tax under N.J.S.A. 54:10A-5, the 6.625% state sales tax under N.J.S.A. 54:32B-3, withholding tax, the Business Alternative Income Tax (BAIT) under N.J.S.A. 54A:12-1 et seq., the New Jersey inheritance tax under N.J.S.A. 54:34-1 et seq., and the New Jersey Closing Agreement program under N.J.S.A. 54:53-1.

New Jersey Tax Court — in Trenton

The state's specialized tax tribunal, established 1979 and seated at the Richard J. Hughes Justice Complex, 25 Market Street, 7th Floor, Trenton NJ 08611 — one block from the Division of Taxation headquarters. Hears disputes between taxpayers and the Director of the Division of Taxation, the State Treasurer, and municipal tax assessors. 90-day complaint deadline from a Final Determination of the Director under N.J.S.A. 54:51A-14. Decisions are appealable to the Superior Court of New Jersey, Appellate Division (also seated in Trenton). Victory Tax Lawyers refers New Jersey Tax Court litigation to locally admitted New Jersey counsel; we handle the federal portion and the Division of Taxation administrative work directly.

City of Trenton Finance Department

The municipal finance authority for Trenton, at City Hall, 319 East State Street, Trenton NJ 08608. Administers Trenton property-tax billing and collection. The Mercer County Board of Taxation at 1440 Parkside Avenue, Ewing NJ 08638 hears property-tax assessment appeals under N.J.S.A. 54:3-21.

Mercer County Treasurer and County Clerk

The county finance authority for Mercer County, with the County Treasurer at 640 South Broad Street, 4th Floor, Trenton NJ 08611, and the County Clerk's office where Notices of Federal Tax Lien and New Jersey Certificates of Debt are recorded against Mercer County real property. NFTLs encumbering downtown Trenton, Hamilton, Ewing, Lawrence, West Windsor, Hopewell, Pennington, and Princeton Junction property are recorded with the Mercer County Clerk.

U.S. District Court — District of New Jersey, Trenton 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 District of New Jersey, Trenton Division — Clarkson S. Fisher U.S. Courthouse, 402 East State Street, Trenton NJ 08608, four blocks from the State House. The Newark Division at 50 Walnut Street and the U.S. Court of Federal Claims in Washington, D.C. are alternative federal venues for refund litigation.

IRS Independent Office of Appeals

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

Taxpayer Advocate Service — New Jersey

An independent organization within the IRS that helps when normal channels stall. The New Jersey Local Taxpayer Advocate office serves taxpayers across the state from Springfield. Page: taxpayeradvocate.irs.gov.

Pennsylvania Department of Revenue (for PA-NJ commuters)

For Trenton residents working in Pennsylvania (Morrisville one mile west, Bucks County, or Philadelphia 30 miles south), the PA-NJ reciprocity agreement of 1977 means Pennsylvania does not tax the wages — only New Jersey does. The reverse applies to Pennsylvania residents working in Trenton or anywhere in New Jersey. Form NJ-165 (PA resident) or Form REV-419 (NJ resident working in PA) prevents wrong-state withholding. The Pennsylvania Department of Revenue handles refund claims if withholding was taken in error: revenue.pa.gov.

Speak with a tax attorney about your Trenton matter

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Frequently asked questions — Trenton tax

Why is the New Jersey top income-tax rate so high?

New Jersey's graduated Gross Income Tax under N.J.S.A. 54A:2-1 runs from 1.4% on the first $20,000 to 10.75% on income above $1 million for single filers and $500,000 for joint filers (the 10.75% bracket was added in 2018 and made permanent in 2020 when the "millionaire's tax" floor was lowered). The 10.75% rate is the third-highest state income tax in the country, trailing only California (13.3%) and Hawaii (11.0%). Combined with federal 37%, FICA Medicare 2.35%, and the federal cap on the SALT deduction at $10,000 per IRC § 164(b)(6), a Trenton top-bracket resident faces an effective combined marginal rate close to 50%. The Corporation Business Tax under N.J.S.A. 54:10A-5 sits at 11.5%, also among the highest in the country.

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

Two regular trial locations are roughly equidistant. The Philadelphia trial location sits at the James A. Byrne U.S. Courthouse, 601 Market Street, Philadelphia PA 19106, about 65 miles southwest of Trenton on I-95 — a one-hour drive in light traffic. The Newark trial location sits at 970 Broad Street, Newark NJ 07102, about 55 miles northeast on the New Jersey Turnpike — an hour to ninety minutes depending on traffic. A Trenton taxpayer may designate either location when filing the Tax Court petition; the Court honors the request when scheduling permits. 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 — one day late and the federal assessment becomes final.

I live in Trenton and work in Pennsylvania — do I owe Pennsylvania tax?

No. The 1977 Pennsylvania-New Jersey Reciprocal Personal Income Tax Agreement provides that a New Jersey resident working in Pennsylvania pays only New Jersey personal income tax on those wages, and not Pennsylvania PIT. To prevent Pennsylvania withholding at the start of employment, file Form REV-419 with your Pennsylvania employer claiming exemption from PA withholding based on New Jersey residency. Your wages are taxed by New Jersey under N.J.S.A. 54A:5-1 as resident income. The reverse rule applies for a Pennsylvania resident working in Trenton or elsewhere in New Jersey: file Form NJ-165 with the New Jersey employer and only Pennsylvania PIT applies. Local Pennsylvania Earned Income Tax (the local-level wage tax administered by Berkheimer, Keystone, or other local collectors) is not covered by the reciprocity agreement; that piece may still apply depending on the Pennsylvania municipality where the employer is located. Philadelphia's separate Wage Tax also applies to wages earned within city limits regardless of residency.

I'm a State of New Jersey employee — why did my retirement-year tax bill come in so high?

The most common cause is the combined effect of a final-year vacation and sick-time lump-sum payout, a State Deferred Compensation Plan distribution, and a Public Employees' Retirement System (PERS) pension that starts mid-year. The lump-sum payout is taxed as supplemental wages at the default 22% federal withholding rate — well below the actual marginal rate for a senior career employee whose combined wages plus deferred-comp distribution push the year's income into a higher bracket. Add 10.75% New Jersey at the top bracket and a five- or six-figure April balance due is routine. The fix at the planning stage is a quarterly Form 1040-ES under IRC § 6654 in the retirement year, a §72(t)(2)(F) early-distribution exception analysis if you separated before 55, and a careful PERS basis-recovery calculation on the pension portion (New Jersey allows pre-tax PERS contributions to be recovered tax-free under N.J.A.C. 18:35-2.5).

I'm a Princeton post-doctoral fellow — is my stipend taxable?

Almost always, yes. IRC § 117 excludes from gross income amounts received as a "qualified scholarship" by a degree candidate at a qualifying educational institution, used for qualified tuition and related expenses. Post-doctoral fellows are not degree candidates — you have already received your doctorate. IRC § 117(c) is the controlling rule: amounts representing payment for past, present, or future teaching, research, or other services required as a condition of receiving the fellowship are includible in gross income, even when labeled a "fellowship" or "stipend." Princeton, the Institute for Advanced Study, and Princeton Theological Seminary post-doctoral stipends typically fall under §117(c) and are reported to you on Form W-2 (employee post-doc) or Form 1099-MISC (non-employee post-doc) and taxed as wages or self-employment income. Health-insurance subsidies, housing allowances, and travel reimbursements may or may not be excludible depending on the specific facts; we run the analysis on a per-component basis.

I'm a Princeton Theological Seminary graduate serving as a Trenton-area pastor — how does §107 work?

IRC § 107 excludes from gross income a "minister of the gospel's" parsonage allowance. Two forms apply: §107(1) covers in-kind housing furnished by the congregation (the entire fair rental value is excludible), and §107(2) covers a cash housing allowance, excludible up to the lesser of (a) the amount actually used for housing expenses, (b) the fair rental value of the home plus furnishings and utilities, or (c) the amount designated by the employing church in advance of payment. The "designation in advance" requirement is the most commonly fumbled element — the church must affirmatively designate the housing allowance in a board resolution, employment contract, or budget action before the first dollar is paid for the year. The §107 exclusion does not extend to self-employment tax: under IRC § 1402, the excluded parsonage allowance is added back for SECA purposes, producing a 15.3% self-employment tax bill that often surprises new clergy. Princeton Theological Seminary's pension-board and Diocese of Trenton clergy face this routinely.

What is the New Jersey Tax Court and what is its deadline?

The New Jersey Tax Court is the state's specialized tax tribunal, established 1979 and seated right here in Trenton at the Richard J. Hughes Justice Complex, 25 Market Street, 7th Floor — one block from the Division of Taxation headquarters. It hears disputes between taxpayers and the Director of the Division of Taxation, the State Treasurer, and municipal tax assessors. The complaint deadline is 90 days from a Final Determination of the Director under N.J.S.A. 54:51A-14, aligned with the federal Tax Court 90-day deadline. Decisions are appealable to the Superior Court of New Jersey, Appellate Division (also seated in Trenton). Victory Tax Lawyers refers New Jersey Tax Court litigation to locally admitted New Jersey counsel; we handle the federal portion and the Division of Taxation administrative work directly. The geography helps Trenton residents: a Tax Court complaint, hearing, and decision all happen within the city limits.

My family member died in New Jersey — do I owe estate tax, inheritance tax, or both?

New Jersey repealed its estate tax effective January 1, 2018, so for deaths after that date there is no New Jersey estate tax. The state retained its inheritance tax under N.J.S.A. 54:34-1 et seq., which is graduated by beneficiary class: Class A (spouse, parent, grandparent, child, grandchild, other lineal descendants) is fully exempt; Class C (siblings, sons-in-law, daughters-in-law) pays 11% on the first $1.075 million and 13% to 14% above; Class D (everyone else — nieces, nephews, cousins, friends, charities not separately exempted, business partners) pays 15% to 16%. New Jersey is one of only two states (Maryland is the other) with this kind of relationship-based state-level death-transfer tax. Form IT-R is filed with the Inheritance Tax Branch of the Division of Taxation at 3 John Fitch Way in Trenton. The federal estate tax under Form 706 ($13.61M exemption for 2024) is a separate layer that applies regardless of beneficiary class.

I founded a Princeton spinout — can I exclude my gain on sale under §1202?

Possibly. IRC § 1202 excludes from gross income gain on the sale of "qualified small business stock" (QSBS) held more than five years, up to the greater of $10 million per issuer or 10x basis. The stock must have been acquired at original issuance directly from the corporation (or through a §351 exchange that preserves the §1202 status), the issuer must have been a domestic C-corporation with aggregate gross assets of $50 million or less at the time of issuance and immediately afterward, and at least 80% of the corporation's assets must have been used in an active business other than excluded fields (which include certain professional services, financial services, hospitality, and natural-resource extraction, but explicitly include qualified technology and biotechnology businesses common in Princeton spinouts). The five-year holding period is firm — a sale at year four-and-a-half eliminates the exclusion. The §1045 rollover lets you defer the gain into another QSBS investment if you sell before five years; planning for the rollover requires action within 60 days of the sale. We coordinate the §1202 analysis with founders before any liquidity event.

Can I be audited by both the IRS and the New Jersey Division of Taxation for the same year?

Yes. The IRS and the New Jersey Division of Taxation operate independently and share information through the IRS-state exchange program. A federal audit adjustment is routinely reported to New Jersey under the state's federal-change reporting rule at N.J.S.A. 54A:8-7, and vice versa. We coordinate the two audits to prevent inconsistent positions on the federal record from costing you on the New Jersey return — particularly important given New Jersey's 10.75% top marginal rate, which produces a sizable state liability on any upward federal adjustment.

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

New Jersey does not use the term "Offer in Compromise" but operates a functionally similar program under N.J.S.A. 54:53-1 called the Closing Agreement program, which permits the Division of Taxation to settle a disputed tax for less than the full amount where doubt as to collectibility or doubt as to liability exists. The Division publishes a Closing Agreement Application for individual and business tax liabilities; all New Jersey returns must be filed before consideration, and a financial-disclosure package is required. The agency reviewer sits at 3 John Fitch Way in Trenton, which often shortens the back-and-forth compared with multi-region states. We typically run a state Closing Agreement in parallel with a federal Offer in Compromise where both debts are real.

What is the New Jersey BAIT and should I elect it?

The New Jersey Business Alternative Income Tax (BAIT) under N.J.S.A. 54A:12-1 et seq. is an elective pass-through entity tax enacted in 2020 as a federal SALT-cap workaround. A New Jersey S-corporation, partnership, or LLC taxed as a partnership may elect to pay the state Gross Income Tax at the entity level (graduated rates capped at 10.9%), with each member receiving a refundable credit for their share of the BAIT paid. The federal deduction is taken by the entity, bypassing the $10,000 SALT cap on the individual return. For Trenton lobbying practices, Princeton-area professional-services firms, and Mercer County medical groups, the BAIT election is usually a substantial federal-tax benefit. Coordination with any parallel Pennsylvania elective PTE tax (for partners or members who are Pennsylvania residents working through reciprocity) requires care to avoid double-counting credits.

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

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 the Philadelphia location and the Newark location. For New Jersey Division of Taxation administrative work at the John Fitch Way headquarters, we file Form M-5008-R Appointment of Taxpayer Representative and handle the matter remotely. For formal litigation in the New Jersey Tax Court at the Hughes Justice Complex or a Superior Court Appellate Division proceeding, we co-counsel with locally admitted New Jersey 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). New Jersey follows a parallel filing-compliance posture; the Division may assess based on the federal-change reporting rule or estimate tax under N.J.S.A. 54:49-6 when a taxpayer fails to file. For PA-NJ reciprocity filers, both states' returns must be brought current together — a federal Streamlined Filing alone leaves the state exposure live, and Pennsylvania withholding adjustments may need to be unwound.

Can the IRS levy my Trenton 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 PNC Bank, Bank of America, TD Bank, Wells Fargo, Valley National, Provident Bank, First Bank, or any New Jersey-chartered institution, and serve wage levies on Trenton-area employers including the State of New Jersey payroll, Capital Health, St. Francis Medical Center, Robert Wood Johnson University Hospital Hamilton, Princeton University, the Institute for Advanced Study, Thomas Edison State University, Mercer County government, and the Trenton Public School District. 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). New Jersey issues parallel state Certificates of Debt under N.J.S.A. 54:49-12 that function as Superior Court judgment liens.

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. A New Jersey state Closing Agreement under N.J.S.A. 54:53-1 typically runs four to nine months on a parallel track at the John Fitch Way headquarters.

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. New Jersey state collection follows a similar pattern: a Form M-5008-R routes Division of Taxation contact, and a pending Closing Agreement under N.J.S.A. 54:53-1 pauses state Certificate-of-Debt 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: May 26, 2026. Editorial standard: every federal-statute citation links to law.cornell.edu (Legal Information Institute, Cornell Law School). Every New Jersey statute citation references the New Jersey Statutes Annotated (N.J.S.A.). 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 New Jersey Division of Taxation, the U.S. Tax Court, the New Jersey Tax Court, 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 New Jersey or the Commonwealth of Pennsylvania; where a New Jersey state-court appearance, New Jersey Tax Court litigation, or a Pennsylvania Board of Finance and Revenue proceeding 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.

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. § 107 — Parsonage Allowance
26 U.S.C. § 117 — Qualified Scholarships
26 U.S.C. § 1202 — Qualified Small Business Stock Exclusion
26 U.S.C. § 1402 — Self-Employment Income and Minister Income
26 U.S.C. § 174 — Research and Experimental Expenditures
26 U.S.C. § 6038D — Foreign Financial Asset Reporting
N.J.S.A. 54A:2-1 — New Jersey Gross Income Tax rates
N.J.S.A. 54A:5-1 — New Jersey resident source-of-income rules
N.J.S.A. 54A:12-1 — Business Alternative Income Tax (BAIT)
N.J.S.A. 54:10A-5 — Corporation Business Tax rate
N.J.S.A. 54:32B-3 — New Jersey sales and use tax
N.J.S.A. 54:34-1 et seq. — New Jersey inheritance tax (Class A / C / D)
N.J.S.A. 54:49-4 — New Jersey failure-to-file penalty
N.J.S.A. 54:49-6 — Notice of Deficiency and assessment authority
N.J.S.A. 54:49-12 — Certificate of Debt as Superior Court judgment
N.J.S.A. 54:50-8 — Responsible-person liability for withheld and sales tax
N.J.S.A. 54:51A-14 — 90-day New Jersey Tax Court complaint window
N.J.S.A. 54:53-1 — New Jersey Closing Agreement program
1977 Pennsylvania-New Jersey Reciprocal Personal Income Tax Agreement — PA-NJ wage reciprocity
72 P.S. § 7301 — Pennsylvania Personal Income Tax (for PA-NJ reciprocity cross-reference)