BACK TAXES NEVER GO AWAY ON THEIR OWN! GET RELIEF NOW!

Facing disputes with taxing authorities requires experience, precision, and strategic advocacy. DEEN ARANS (DA)’s Tax Resolution Practice represents both individuals and businesses in complex federal, state, and local tax matters—delivering solutions that protect financial interests, restore compliance, and provide peace of mind.

Our professionals are licensed CPAs and tax advisors. In accordance with IRS Circular 230, we inform you that any advice provided in this communication is not intended or written to be used, and cannot be used, for the purpose of avoiding penalties under U.S. federal tax law.

Our Approach

We follow a structured, partner-led methodology to ensure effective resolution:

1. Assessment & Risk Analysis
       Comprehensive review of tax exposure, compliance gaps, financial capacity, and procedural posture.
2. Strategic Resolution Planning
       Evaluation of all available options and development of a tailored strategy aligned with IRS, state, or local regulations.
3. Representation & Advocacy
       Acting as the primary point of contact with taxing authorities—managing audits, collections, appeals, and negotiations.
4. Resolution & Compliance Restoration
       Implementing approved resolutions and establishing forward-looking compliance frameworks.

Tax Controversy & Audit Representation

We represent clients before the IRS and state taxing authorities during examinations and disputes.

Services include:

• IRS and state tax audits
• Correspondence and field examinations
• Appeals representation
• Examination defense and documentation support
• Statute and procedural analysis

Focus:
Minimizing exposure, protecting taxpayer rights, and resolving disputes efficiently.

Collections & Enforcement Resolution

When tax liabilities escalate into collection actions, timely intervention is critical.

Services include:

• Installment agreements
• Offers in compromise
• Lien and levy release negotiations
• Wage garnishment and bank levy resolution
• Currently Not Collectible (CNC) status

Outcome:
Structured repayment or settlement solutions aligned with financial reality.

Penalty Abatement & Interest Relief

We seek relief from excessive penalties and interest where reasonable cause or administrative error exists.

Services include:

• First-time penalty abatement
• Reasonable cause submissions
• Interest abatement requests
• Administrative appeals

Compliance Remediation & Voluntary Disclosure

We help clients correct non-compliance while minimizing enforcement risk.

Services include:

• Back tax return preparation and filing
• Payroll tax compliance remediation
• Information reporting corrections
• Voluntary disclosure strategy and execution

Benefit:
Restored compliance with reduced exposure to penalties and enforcement.

Business & Payroll Tax Resolution

Tax issues affecting businesses often require specialized handling.

Services include:

• Payroll tax disputes and trust fund recovery matters
• Responsible person investigations
• Sales and use tax resolution
• Multi-state tax controversy

Who We Serve

• Individuals
• Privately held businesses
• Executives and high-net-worth individuals
• Real estate investors and developers
• Entrepreneurs and closely held entities
• Organizations facing multi-jurisdictional tax exposure

SERVICES FOR INDIVIDUALS

We help individuals navigate audits, collections, and disputes with the IRS and state authorities.

Key Services:

• IRS audits and appeals
• Installment agreements and offers in compromise
• Penalty and interest abatement
• Wage garnishment or levy resolution
• Voluntary disclosure of unfiled or late returns

Case Study – Individual:

A.   High-Net-Worth Executive

Client Profile
A high-net-worth executive with complex compensation, equity-based income, and multi-state filing obligations.

Exposure
The client had multiple years of unfiled federal and state income tax returns, resulting in substitute-for-return assessments, materially overstated liabilities, and significant penalties and interest. In addition to collection risk, the matter posed professional and reputational concerns.

Engagement & Technical Approach
DA’s Tax Resolution team initiated a full compliance remediation engagement, including multi-year return preparation and reconciliation of executive compensation, equity events, and related disclosures. IRS and state transcripts were analyzed to identify assessed liabilities and procedural posture.

Once compliance was restored, we evaluated collection alternatives, including an Offer in Compromise, based on the client’s reasonable collection potential (RCP). Our analysis incorporated statutory and administrative considerations, including income streams, asset equity, liquidity constraints, and allowable expense standards, without disrupting ongoing professional obligations.

In parallel, we pursued penalty abatement and presented documented grounds for administrative relief.

Resolution
The IRS accepted the Offer in Compromise, resolving the matter for a fraction of the originally assessed balance. Penalties were reduced by over 70%, and all collection activity was terminated. The client was restored to full federal and state compliance.

Result
Material reduction of tax exposure, restored compliance standing, and protection of the client’s financial and professional reputation.

NOTE:  This example reflects an engagement performed by our firm. Client details have been anonymized to protect confidentiality. 

Tax resolution outcomes depend on individual facts, documentation, and determinations by taxing authorities and are not guaranteed.

B.   Family Office / Private Equity Principal

Client Profile
A family office principal / private equity executive with pass-through interests, investment income across multiple entities, and multi-state filing requirements.

Exposure
Several years of unfiled federal and state returns resulted in significant assessed liabilities, penalties, and interest due to incomplete information. The complexity of the client’s investment structure increased both financial exposure and administrative risk.

Engagement & Technical Approach
DA’s Tax Resolution Services team coordinated a comprehensive compliance remediation strategy, overseeing the preparation and filing of all delinquent returns across affected jurisdictions. This included reconciliation of partnership income, investment activity, and related disclosures to replace substitute assessments with accurate filings.

Following compliance restoration, we performed a detailed evaluation of IRS collection alternatives, including Offer in Compromise eligibility. Our analysis focused on the potential for reasonable collection, taking into account asset structure, cash flow, valuation considerations, and IRS financial disclosure requirements, while preserving the long-term investment strategy and liquidity.

We also pursued penalty abatement and presented substantiated requests for administrative relief where appropriate.

Resolution
The IRS approved an Offer in Compromise and granted significant penalty relief, reducing the overall liability by more than 75% and concluding active collection efforts. Compliance was fully restored across all jurisdictions.

Result
The engagement delivered a predictable, controlled resolution, reduced tax exposure, and enhanced administrative stability—allowing the family office to refocus on investment management and long-term planning.

NOTE:  This example reflects an engagement performed by our firm. Client details have been anonymized to protect confidentiality. 

Tax resolution outcomes depend on individual facts, documentation, and determinations by taxing authorities and are not guaranteed.

SERVICES FOR BUSINESSES

We represent businesses in complex payroll, income, and sales tax matters—ensuring regulatory compliance while minimizing risk.

Key Services:

• Payroll tax disputes and trust fund recovery resolution
• Sales, use, and excise tax audits
• Multi-state tax controversy
• Responsible person investigations
• Compliance remediation and voluntary disclosure

Case Study – Business Payroll Tax Audit Defense, Multi-State Compliance Remediation & TFRP Risk Mitigation Engagement
A mid-sized manufacturing company faced a multi-state payroll tax audit with potential trust fund recovery penalties. DA’s team conducted a full review, prepared documentation, and negotiated with state authorities, resulting in a settlement that reduced the liability by 60% while preserving business operations and protecting executives from personal liability.

Client Profile
A mid-sized manufacturing company with operations and employees in multiple states, utilizing a combination of in-house payroll processing and third-party payroll service providers.

Facts & Risk Exposure
The company was selected for a multi-jurisdiction payroll tax audit involving federal employment taxes and corresponding state withholding and unemployment filings. Initial audit findings identified discrepancies in payroll tax deposits, filing timeliness, and interstate reporting consistency. As the examination expanded, the company faced potential assessment of back employment taxes, failure-to-deposit penalties, accrued interest, and heightened exposure to Trust Fund Recovery Penalties (TFRP) for individuals deemed responsible for payroll tax compliance.

Engagement Scope & Technical Analysis
Our Tax Resolution team was engaged to assume full representation and manage audit risk. The engagement included:

• Detailed reconciliation of payroll registers to Forms 941, state withholding returns, Forms W-2/W-3, and payment records
   
• Review of IRS and state agency account transcripts to identify assessed and proposed liabilities
   
• Analysis of payroll tax deposit timing and classification issues across jurisdictions
   
• Evaluation of internal controls, authorization authority, and payroll oversight to assess potential responsible person exposure under TFRP criteria
   
• Coordination of audit responses across federal and state taxing authorities to ensure consistency and prevent duplicative or conflicting assessments
   

Compliance remediation was prioritized to stabilize the examination and preserve resolution options.

Resolution Strategy & Representation
Our strategy focused on narrowing audit scope, correcting factual discrepancies, and mitigating both corporate and individual exposure. We represented the company in all communications with examining agents, provided substantiated documentation, and addressed procedural and technical issues raised during the audit.

Where adjustments were unavoidable, we negotiated penalty mitigation and advised management on restructuring payroll oversight and documentation to reduce future risk. Importantly, we proactively addressed TFRP considerations by clarifying roles, decision-making authority, and payment controls—ultimately preventing assertion of personal liability against company officers.

Outcome
The audit concluded with reduced proposed assessments and no Trust Fund Recovery Penalties asserted. Remaining payroll tax liabilities were resolved through an agreed-upon payment arrangement that preserved cash flow and operational continuity. The company implemented enhanced multi-state payroll compliance protocols and internal controls as part of the resolution.

Result

The company achieved audit closure, restored compliance across jurisdictions, and materially reduced both financial exposure and executive risk, resulting in a settlement that reduced the liability by 60% while preserving business operations and protecting executives from personal liability — allowing leadership to refocus on manufacturing operations and strategic growth.
NOTE:  This example reflects an engagement performed by our firm. Client details have been anonymized to protect confidentiality. 

Tax resolution outcomes depend on individual facts, documentation, and determinations by taxing authorities and are not guaranteed. 

PENALTY ABATEMENT & COMPLIANCE REMEDIATION

We represent Individuals, Businesses, and high-net-worth individuals in penalty abatement and compliance remediation cases.

Services include:

• First-time and reasonable cause penalty abatement
• Interest abatement requests
• Compliance remediation plans for both individuals and businesses
• Voluntary disclosure to IRS and state agencies

Case Study – Penalty Abatement & Compliance Remediation Engagement:
Client Profile
A sophisticated real estate investor with multiple pass-through entities and a diversified rental portfolio, reporting income across several jurisdictions.

Facts & Circumstances
The client incurred substantial IRS late-filing penalties after multiple returns were filed beyond statutory deadlines. The delays arose from a series of unforeseen personal events that disrupted normal financial administration. While the underlying tax liabilities were not material relative to the client’s net worth, cumulative failure-to-file penalties and accrued interest significantly increased the total exposure, leading to IRS enforcement notices.

Engagement Scope & Analysis
Our engagement began with a comprehensive tax compliance and resolution review, including:

• Analysis of IRS account transcripts and penalty assessments
   
• Verification of filing completeness and accuracy across individual and related entity returns
   
• Review of rental activity reporting, depreciation schedules, and passive activity limitations
   
• Evaluation of eligibility for administrative penalty relief under applicable IRS guidelines
   

We prioritized restoring full compliance as a prerequisite to resolution, ensuring all delinquent and current-year filings were properly submitted and reconciled.

Resolution Strategy & Execution
Based on the client’s facts and documentation, we prepared and submitted a formal penalty abatement request grounded in reasonable cause standards, supported by contemporaneous records and a clear chronology of events. We represented the client in direct communications with the IRS, responding to inquiries and managing procedural follow-up to resolution.

Outcome
The IRS approved an abatement of a significant portion of late-filing penalties, materially reducing the client’s outstanding balance. With compliance fully restored, we implemented forward-looking filing and payment protocols designed to support the client’s ongoing real estate investment activities and minimize future exposure.

Result
The client achieved a reduced tax burden, restored compliance standing, and improved certainty around tax administration—allowing greater focus on portfolio management and long-term planning.

NOTE:  This example reflects an engagement performed by our firm. Client details have been anonymized to protect confidentiality. 

Tax resolution outcomes depend on individual facts, documentation, and determinations by taxing authorities and are not guaranteed.

HIGH NET-WORTH INDIVIDUAL TAX RESOLUTION ENGAGEMENT

The Situation
A high-income individual with ownership interests in multiple businesses contacted our firm after receiving IRS collection notices for several years of underreported income and unpaid tax liabilities. The client was concerned about escalating penalties, potential enforcement actions, and the impact on personal and business finances.

Our Approach
We began with a comprehensive review of the client’s tax filings, financial statements, and IRS transcripts to identify the scope of exposure and available resolution options. Our team brought the client into full compliance, corrected prior filings where necessary, and developed a resolution strategy aligned with the client’s cash flow and long-term financial objectives. We then represented the client in direct communications with the IRS.

The Resolution
Through careful negotiation, we secured a structured installment agreement and obtained penalty relief, significantly reducing the overall burden. The resolution halted collection activity, provided a clear path forward, and preserved liquidity while minimizing disruption to the client’s business operations.

The Outcome
The client achieved compliance, predictable tax payments, and peace of mind—allowing them to refocus on business growth and personal financial planning.

NOTE:  This example reflects an engagement performed by our firm. Client details have been anonymized to protect confidentiality. 

Tax resolution outcomes depend on individual facts, documentation, and determinations by taxing authorities and are not guaranteed.

WHY DEEN ARANS (DA)

• Partner-Led Representation – Senior tax professionals lead every engagement,      ensuring accountability and quality.
• Regulatory Expertise – Deep knowledge of IRS, state, and local tax laws and procedural requirements.
• Ethical Advocacy – All actions are performed with integrity and in accordance with IRS Circular 230 and professional standards.
• Integrated Advisory Support – Coordination with DA’s accounting, audit, and CFO      teams ensures a comprehensive solution.
• Proven Experience – Decades of successfully resolving complex tax matters for individuals and businesses.

OUR COMMITMENT

Resolving tax issues is not merely about settling liabilities—it is about restoring stability, protecting reputations, and enabling clients to move forward confidently. DA professionals provide clear guidance, strategic solutions, and measurable outcomes tailored to each client’s circumstances.

TAKE THE NEXT STEP

If you or your business face audits, collection actions, or unresolved tax liabilities, our Tax Resolution professionals are ready to assist.

→ Contact DEEN ARANS (DA) Tax Resolution Team member, Gbenga Aranmolate, at 

(301) 270-4145 or complete our new clients' form.