Tax Attorney

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Nationwide Tax Defense Services. Serious Firepower for Serious Tax Problems!

IRS problems can be a nightmare! Who do you call when the feelings of panic, fear, despair and frustration seem overwhelming?

IRS problems call for experienced and talented legal assistance. Tax Attorney David Jacquot, JD, LLM, P.A. can help protect you from the Internal Revenue Service. When the IRS turns its attention to you, you need to be ready to fight. You should waste no time in getting the assistance of a qualified tax attorney. With over sixteen years of experience practicing law, including nine years devoted specifically to tax law, tax attorney David Jacquot can be your TAX HERO.

Why do I need a tax attorney?

IRS agents may seem friendly and helpful, but when it comes to tax problems, they are the enemy. Without a talented tax attorney, you may end up paying more or even exposing yourself to criminal prosecution. Don't take the chance of going in to your tax fight unarmed. A courtroom may be a dignified and orderly place, but it is still a battlefield. The IRS is not concerned with your well-being; they are only concerned with winning. Only tax attorneys have all the skills and tools necessary to win your fight.

www.4taxhero.com

Tax Related Books 

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Tax, Estate Planning and Business Law. Innovative and Aggressive Representation for Your Legal Needs.

IRS Audits 

Effective IRS Audit Law Attorney

An IRS audit may be the beginning of a difficult process that can lead to tax penalties and even criminal prosecution. Tax Attorney David Jacquot, JD, LLM, P.A. can assist you in managing this process while minimizing the strain it puts on you or your business.

An audit is a procedure used by the Internal Revenue Service to gather information about your income tax return and determine if the information you provided was accurate. The IRS will ask for all evidence it feels is relevant to the information on your tax return. Typically they will request information from the taxpayer and sources related to the taxpayer (banks, employers, customers, etc.). In the audit process you only need to provide the IRS the information needed to prove YOUR case and not everything that they request. Occasionally, the IRS will request information that is not relevant. Information, such as customer lists, may be requested even when the information is not clearly relevant to your tax return. If we cannot convince the IRS to retract these requests, it may become necessary to ask the Court to quash the Summons in order to protect you and your business. Only a tax attorney can handle these proceedings.

At the end of the audit, the Revenue Agent will prepare a report regarding the
audit. In this report he or she may recommend changes to your return. This report will be reviewed by a supervisor and if additional tax, penalties, or interest is proposed a "30 Day Letter" is issued. The "30 Day Letter" informs you of the audit recommendations and gives you 30 days to request review by an appeals officer. If you file a protest within the 30 days, your case moves to appeals. If you do not file a protest within 30 days, a Notice of Deficiency or "90 Day Letter" will be issued. This "90 Day Letter" is your ticket to the U.S. Tax Court.There is no requirement that you appear at an audit meeting. Typically we do not
have our clients appear. If there are questions we cannot answer, we request that they be presented in writing and we will respond in writing. This process of written questions and answers makes ensures that there are no misunderstandings or miscommunication.

At the end of an audit, the IRS may propose additional tax, penalties, or interest be assessed in the form of a"30 Day Letter". The "30 Day Letter" informs you of the audit recommendations and gives you 30 days to request review by an appeals officer.

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IRS Appeals 

Need IRS Tax Help? Attorney David Jacquot Will Fight for You.

When an IRS audit ends up in an audit recommendation you do not agree with, tax attorney David Jacquot, JD, LLM, P.A. can represent you before the Appeals Office. Appeals Officers are often more experienced than the Revenue Agents who handle audits. The vast majority of disputed audits are settled during the appeals process. It is important to have someone who understands the procedure and has been there before. The IRS handles many appeals every year; you are only involved in one.

An aggressive and knowledgeable tax lawyer can make a huge difference in the settlement you will be offered during the appeals process. Like the taxpayers themselves, the IRS does not want to litigate these issues because of the time, expense, and risk of an unfavorable outcome. When the IRS loses a case, it sets a precedent that could cost them for years. A powerful tax disputes attorney on your side gives the IRS the maximum opportunity to lose. To avoid such a loss, the Appeals Officers look to settle these matters and avoid the courtroom altogether.

If the matter cannot be settled at appeals, the Appeals Officer will issue a Notice of Deficiency or "90 Day Letter". This "90 Day Letter" is your ticket to the U.S. Tax Court. You can proceed to the U.S. Tax Court without paying the alleged tax owed if you file your petition in the Tax Court within 90 days of the issuance of the Notice of Deficiency. If you do not file a petition in Tax Court within 90 days, the proposed tax changes, interest, and penalties become assessed and owed.

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IRS Collections Actions 

Fight IRS Debt Collection Actions with Tax Attorney David Jacquot

The best chance to resolve your tax dispute successfully is before the tax is assessed. If you could not secure a satisfactory settlement during the IRS audit and appeals stage, or in tax court, the tax will be assessed. Tax Attorney David Jacquot, JD, LLM, P.A. can help you fight the validity of the tax, or obtain collection relief in certain circumstances.

For the last nine years, we have focused our practice on tax disputes and tax issues. With more than sixteen years of courtroom experience, David Jacquot knows how to go to battle for you. Our office understands what it takes to fight the IRS. Knowledge, preparation, and an aggressive approach can produce excellent results in these cases. With more than nine years of active duty service in the United States Army, Mr. Jacquot is no stranger to hard work and preparation. After his military career was cut short due to injury, he continued to fight for people through the law. He obtained his LLM in taxation (a masters in tax law) to gain the knowledge he needed to win these fights. The government has broad powers when it comes to IRS debt collection actions, but there are tools that taxpayers can use to limit these collections.

The most commonly employed tools are the offer in compromise and installment agreements. Those who advertise the ability to settle for "pennies on the dollar" are often referring to the offer in compromise program. The IRS has issued a warning against some of these companies and no one can promise you such a settlement without extensive consultation about your particular situation.

IRS Books 

The Fair Tax Book: Saying Goodbye to the Income Tax and the IRS

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What the IRS Doesn't Want You to Know: A CPA Reveals the Tricks of the Trade

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Don't Let The Irs Destroy Your Small Business: Seventy-six Mistakes To Avoid

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Tax News 

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Offers in Compromise 

Filing an Offer in Compromise? Attorney David Jacquot Can Help.

The Offer in Compromise program was established to grant relief, in certain situations, to people assessed with a tax. Tax Attorney David Jacquot, JD, LLM, P.A. can advise you on your eligibility to meet the requirements of the program. An Offer in Compromise is not the best option a taxpayer can get. It is important to determine if the tax liability can be avoided at the audit, appeal, or tax court level before beginning the payment option of an Offer in Compromise. Attorney Jacquot has over sixteen years of experience practicing law, including the last nine years dedicated to handling tax disputes.

Our tax law practice focuses on providing the best possible service to our clients. It is always better to avoid the tax liability than to turn immediately to payment options. Do not surrender your rights without a fight. Late night television is full of people advertising services that promise to settle your tax debt for "pennies on the dollar." These services are generally not attorneys, and are basically Offers in Compromise mills. They fill out the forms, regardless of the clients' individual situation, and make an offer. These offers are often not accepted by the IRS. The IRS has even gone so far as to release a consumer alert advising taxpayers to beware of these "pennies on the dollar" claims.

If you do qualify for the Offer in Compromise program because the IRS has doubts about the tax liability, doubts about their ability to collect the debt, or undue hardship involved in paying the debt, it is best to have an experienced and knowledgeable tax attorney to help you present your arguments. The chances of a successful petition are much better with an efficient Offer in Compromise attorney on your side.

Offer in Compromise Video 

Offer in Compromise | IRS Tax Debt Relief

YOUTUBE INFO The Offer in Compromise program was established to grant tax debt relief to to people who cannot pay their taxes. An Offer in Compromise is not always the best option. It is important to determine if the tax debt liability can be avoided at the audit, appeal, or tax court level. Additionally, there may be ways to avoid collection of taxes that re bettern than the offer in compromise, such as bankruptcy or waiting out he collection statute of limitations. Late night television is full of people advertising services that promise to settle your tax debt for "pennies on the dollar." These services are generally not attorneys, and are basically Offers in Compromise mills. They fill out the forms, regardless of the clients' individual situation, and make an offer. These offers are often not accepted by the IRS. The IRS has even gone so far as to release a consumer alert advising taxpayers to beware of these "pennies on the dollar" claims. If you think you may qualify for the Offer in Compromise program because doubts about the tax liability, doubts about their ability to pay the tax debt, or undue hardship involved in paying the tax debt, it is best to have an experienced and knowledgeable tax attorney help you present your arguments. The vast majority of offer in compromise filings are rejected by the IRS and the chances of a successful petition are much better with an qualified Offer in Compromise attorney on your side. www.4taxhero.com

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Criminal Tax Matters 

Tax Evasion, Failure to File, and Tax Fraud Lawyer David Jacquot

Tax Attorney David Jacquot, JD, LLM, P.A. has extensive trial experience representing clients in criminal matters. For the last nine years, we have focused on fighting for the rights of clients in tax disputes. Criminal tax cases are the most serious types of tax dispute. Tax crimes include:

Tax Evasion
Failure to Collect Taxes
Failure to Pay Over Collected Taxes
Failure to File a Return
Failure to Supply Information to the IRS
Filing a False Return
Submitting False Documents
Money Laundering
Mail Fraud
Other Tax Related Crimes

What is important to remember when you find yourself involved in a criminal tax matter is to secure an experienced tax fraud lawyer as soon as possible. You have the right to remain silent. You should not say anything beyond identifying yourself and requesting an attorney. You do not have to answer questions regarding your tax status, and you should not answer them without first consulting a tax attorney.

If you have not been filing returns, you have knowingly filed false returns, you are delinquent in paying your taxes, or have some other reason to suspect that you might come under IRS investigation, you should retain a tax attorney as soon as possible. When you are subject to prosecution, preparation is all important.

A criminal tax investigation is a fight for your freedom. Our tax law practice has given us substantial insight into IRS practice and procedure. We understand the tactics they use. We can help you fight back against the Internal Revenue Service. Contact an aggressive tax fraud lawyer today to schedule your free initial consultation . We can help you protect yourself.

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Don't Get Sued!!! 

Do Tax Representatives Have a Duty to Protect Clients from Providing Incriminating Information in IRS Audits?

In many cases, a taxpayer with an IRS audit may have exposure to potential criminal charges in addition to potential increased tax liability, penalties and interest. Further, there can often be civil lawsuits related to tax cases (breach of contract, business dissolution, etc). Lastly, there can be adminstrative cases that arise out of the same circumstances that have caused the tax difficulty (state and local tax proceedings, licensing proceedings, etc).

Cases that have potential criminal exposure are often referred to as "eggshell" or "sensitive issue" audits. Cases with civil and administrative issues should also be considered "sensitive issue" audits.
Tax Practitioners that are not attorneys need to be extremely careful in representing clients in "eggshell" audits. The Internal Revenue Service Restructuring and Reform Act of 1998 (P.L.105-206) added a tax practitioner-client privilege. In summary this privilege only applies when "tax" advice is sought.

This "tax practitioner" privilege only applies to tax matters and does not apply to criminal matters. Therefore if the "eggshell" audit turns into a criminal investigation, the taxpayer's representative could be required to disclose all communications that he or she had with the taxpayer. In short, the tax practitioner could become the government's star witness against the tax payer. On the other hand, tax practitioners that are attorneys do have an attorney-client privilege that extends to criminal and most other legal matters.

Additionally, the tax practitioner privilege likely does not apply in civil suits or non-tax administrative hearings. Again this puts the practitioner in the undesirable position to adversely testify against his or her client.

Obviously, a taxpayer is not going to be happy about is representative testifying against him.

If you are a tax practitioner that is not an attorney, this situation raises several important questions:

1. Can a taxpayer sue a tax practitioner for not taking steps to protect them in an "eggshell" audit?

2.How can a tax practitioner tell when a taxpayer may have potential criminal exposure?

3.What can a tax practitioner do to protect themselves?

Fill in the email form below to get a FREE article that explores the answers to these questions.

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Tax Attorney David Jacquot, JD, LLM, P.A. understands tax law and knows how to fight for his clients. For the last nine years, our office has focused...

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