IRS Controversy & Tax Resolution · Scottsdale, Arizona

There is a letter
from the IRS
on your desk.

The pressure you feel is real, and the deadlines are real. But this is a procedure with known steps, known options, and known outcomes — and there are attorneys who handle this every day. Ledgerwood Tax Law has done it hundreds of times.

Confidential Consultation Identify Your Notice

Notice CP14

Tax Year 2023

Balance Due $18,432.00

Response Deadline See your letter

We have calculated your tax for the above tax year and determined you owe a balance. If you agree with our calculations, please pay the full amount. If you disagree, contact us or seek representation.

You have the right to representation. A tax attorney holds attorney-client privilege. Your accountant or enrolled agent does not. Call before you respond.

18+ Years IRS Controversy

Privilege Protected Communications

Flat Fee Per Phase, No Surprises

Scottsdale Statewide & Federal

Notice Decoder

Which IRS notice did you receive?

Select your notice type below. We will explain in plain English what it means, what the deadline pressure is, what happens if it is ignored, and what we do first. Deadlines are stated generally — confirm the exact date on your own letter.

What We Handle

Every dimension of a tax dispute or tax liability.

Tax controversies are rarely simple, and they rarely stay in one category. We handle the full range from the first IRS letter through appeals, collections, and resolution — plus the planning work that prevents the next dispute.

IRS Controversy & Collections Defense

IRS Audits & Examination Representation
Whether the IRS selected your return by formula or through a targeted examination, you are entitled to representation from the first contact. We handle correspondence audits, office examinations, and full field audits. You are not required to speak with an IRS revenue agent directly — and in most cases you should not.
IRS Appeals
If you disagree with an examination result, a collection determination, or a penalty assessment, the IRS Office of Appeals is an independent forum. Appeals resolves the majority of cases that reach it on better terms than the examination division offered. We prepare the protest and represent you through the hearing.
Collections Defense — Liens, Levies & Wage Garnishment
A federal tax lien attaches to all property the moment a tax is assessed and unpaid. A levy actually seizes it — bank accounts, wages, retirement accounts, real estate. We pursue release of liens and levies, installment agreements, and collection due process hearings to stop or reverse enforcement action.
Trust Fund Recovery Penalty & Payroll Tax (Form 941)
The trust fund recovery penalty allows the IRS to hold individual officers, directors, or employees personally liable for unpaid payroll taxes — often for amounts that dwarf the original business debt. We defend responsible-person determinations and negotiate resolution of the underlying 941 liability separately from the personal assessment.
Unfiled Returns & Back Taxes
The IRS can file a substitute return on your behalf under IRC § 6020(b), and it will not claim any deductions or credits you were entitled to. We prepare and file all delinquent returns, negotiate penalty abatement for failure to file, and bring you into compliance before the IRS begins enforced collection.
Worker Classification Disputes
The IRS reclassification of contractors to employees generates substantial employment tax liability, penalties, and interest. We defend Section 530 relief claims, handle Form SS-8 determinations, and represent employers in employment tax audits across all industries.

Specialized & International

Offshore Accounts & FBAR Disclosure
Failure to file a Report of Foreign Bank and Financial Accounts (FBAR) carries civil penalties up to $10,000 per year for non-willful violations, and up to $100,000 or 50% of account value for willful violations. We handle voluntary disclosure, streamlined filing procedures, and defend clients in FBAR penalty proceedings.
Cryptocurrency Reporting
The IRS treats virtual currency as property, meaning every exchange, sale, or use triggers a reportable gain or loss. We advise on proper reporting of crypto income and gains, assist with amended returns to correct prior-year omissions, and represent clients in examinations focused on digital asset transactions.
Criminal Tax Investigation & Eggshell Audits
When civil and criminal exposure coexist — a situation known as an eggshell audit — every statement made to the IRS can be used against you in a criminal proceeding. Attorney-client privilege is not optional in this situation; it is the primary protection you have. We identify when a civil matter has criminal dimensions and structure representation accordingly.
Arizona Department of Revenue Disputes
State tax disputes follow their own procedures and timelines. We handle income tax audits, transaction privilege tax (Arizona's version of sales tax) disputes, and administrative hearings before the Arizona Office of Administrative Hearings and the Arizona Tax Court.
Sales & Use Tax
Arizona's transaction privilege tax applies to vendors, not purchasers — but use tax obligations fall on businesses that purchase goods without paying TPT. We audit TPT exposure, resolve delinquencies, and negotiate with the ADOR.

Tax Planning for Closely Held Businesses

Entity Structuring & S-Corp Elections
Choice of entity is the most consequential tax decision a closely held business makes. We analyze C-corp, S-corp, partnership, and single-member LLC structures against your specific income profile, exit horizon, and ownership composition, then implement the election and operating agreement to match.
Succession Planning
Transferring a closely held business to the next generation or a third-party buyer involves income tax, estate tax, and gift tax consequences that interact in complex ways. We coordinate entity restructuring, installment sale mechanics, family limited partnerships, and grantor trust strategies to achieve a transfer that is efficient across all three taxes.

Resolution Options

Every option on the table — explained honestly.

Select any resolution pathway below to see who it suits, what the IRS requires, how long it typically takes, and the honest catch. No program is right for every taxpayer, and some options are heavily marketed while rarely delivering what is advertised. We will tell you which category you fall into.

Tax documents and financial records on a desk

The Protection That Matters

Why your accountant cannot protect you the way an attorney can.

The most important distinction in a tax dispute is not the one most people know about. Your CPA is an outstanding resource for preparing returns and giving tax advice in ordinary circumstances. But when the IRS contacts you — especially in an examination, an eggshell audit, or a situation that may have criminal dimensions — the rules change fundamentally.

Your Accountant

✗ No attorney-client privilege. Everything you tell your CPA can be subpoenaed — and the IRS routinely does exactly that.
✗ Limited Kovel protection exists only when your accountant is engaged directly by your attorney to assist in rendering legal advice — not when you hire the accountant directly.
✗ A CPA can represent you before the IRS in many matters, but their communications with you are not protected in a criminal referral or a grand jury proceeding.
✗ Enrolled agents carry no privilege at all. They are licensed to practice before the IRS but their advice is fully discoverable.

Your Tax Attorney

✓ Full attorney-client privilege under federal common law and, for tax advice, codified in IRC § 7525 for non-criminal tax matters. What you tell us stays with us.
✓ Work-product protection shields the analysis, strategy memos, and internal documents your attorney prepares in anticipation of litigation or dispute.
✓ In a criminal tax investigation, the Fifth Amendment applies to your testimony — but not to documents you voluntarily gave your accountant. Attorney-client privilege protects communications from the moment engagement begins.
✓ We can engage your CPA as a Kovel accountant, extending the privilege umbrella to their work when they are assisting us in rendering legal advice to you.

The right time to engage a tax attorney is before you respond to any IRS notice — not after you have already spoken to the examiner, provided documents, or received a final assessment. Once information is disclosed, it cannot be taken back.

Representative Results

A selection of client outcomes.

Prior results do not guarantee a similar outcome. Every matter is resolved on its own facts. We do not guarantee settlement amounts or reductions.

Matter Type IRS Assessment / Issue Outcome Duration

Offer in Compromise $412,000 liability Accepted at $28,500 14 months

Trust Fund Recovery Penalty $680,000 personal assessment Assessment reduced; installment at $1,200/mo 8 months

Audit Reconsideration $94,000 self-employment tax Assessment abated in full 6 months

Lien & Levy Release Wage garnishment — $3,400/mo Levy released within 10 days; installment agreement secured 3 weeks

Penalty Abatement $78,000 FTF & FTP penalties Full abatement under reasonable cause 4 months

FBAR Disclosure 3 years unreported accounts Streamlined domestic procedure; non-willful penalty only 5 months

Currently Not Collectible $220,000 balance due CNC status granted; statute running 2 months

The Attorneys

Tax law credentials that matter in controversy work.

The combination of an LL.M. in Taxation, prior IRS experience, and CPA credentials is uncommon in private practice. It is the foundation of this firm.

Graham D. Ledgerwood

Founding Attorney

Arizona Bar No. 024871 — Admitted 2005
LL.M. in Taxation, NYU School of Law, 2006
Former Senior Associate, IRS Office of Chief Counsel (SBSE), Phoenix
J.D., University of Arizona James E. Rogers College of Law, 2005
Admitted: U.S. Tax Court; U.S. District Court, District of Arizona

Graham spent five years as a Senior Associate in the IRS Office of Chief Counsel before entering private practice. In that role, he litigated Tax Court cases, advised revenue agents on examination strategy, and drafted technical advice memoranda on partnership and S-corporation issues. He understands the IRS posture from the inside — which arguments carry weight with Appeals, which revenue agents are authorized to settle, and which cases the IRS will fight to the courthouse steps.

Elena R. Navarro

Partner — Tax Planning & Business Structuring

Arizona Bar No. 031204 — Admitted 2009
LL.M. in Taxation, Georgetown University Law Center, 2010
Certified Public Accountant — Arizona, License No. 23418
J.D., Arizona State University Sandra Day O'Connor College of Law, 2009
Former Tax Manager, Deloitte Tax LLP, Phoenix

Elena holds both a law license and a CPA certificate — a combination that allows her to move between the return-preparation reality and the legal advice context without losing precision in either. Her planning practice focuses on closely held businesses at the inflection points that matter most: initial entity choice, S-corp elections, compensation structuring, and succession. She also leads the firm's state and local tax practice before the Arizona Department of Revenue.

Marcus K. Osei

Associate Attorney — IRS Collections & Controversy

Arizona Bar No. 038552 — Admitted 2018
LL.M. in Taxation, University of Denver Sturm College of Law, 2019
Focus: IRS collections, liens, levies, offer in compromise
J.D., University of Arizona James E. Rogers College of Law, 2018
Volunteer: Community Legal Services, Phoenix Tax Clinic

Marcus joined Ledgerwood Tax Law after completing his LL.M. in Taxation and concentrates on IRS collections matters — the back-end of a tax controversy where enforcement action is imminent or already underway. He manages lien and levy releases, wage garnishment cases, collection due process hearings, and the full offer in compromise process. His background includes a tax clinic serving low-income Arizonans, giving him perspective on both the procedural and human dimensions of collection enforcement.

Fee Structure

Flat fee per phase. No open retainer.

We do not use hourly billing for IRS controversy matters. Every phase of representation is quoted as a flat fee before work begins, so you know the cost of each step before you commit to it. You are never handed a bill you did not agree to in advance.

Phase	What It Includes	Typical Range
Initial Consultation	Review of your notice or situation; preliminary strategy; written summary	No charge
Examination Representation	IRS contact; document management; examination conference; protest if needed	$3,500 – $12,000
IRS Appeals	Written protest; conference preparation; hearing representation	$2,500 – $7,500
Collections Defense	CDP hearing; lien/levy release; installment agreement negotiation	$2,000 – $6,000
Offer in Compromise	Financial analysis; Form 656 preparation; IRS negotiation through acceptance	$4,500 – $9,000
Tax Court Petition	Petition drafting; stipulation; trial preparation and trial	$6,000 – $20,000+
Business Tax Planning	Entity analysis; election filings; operating agreement; succession memo	$2,500 – $8,000

Ranges reflect the complexity and size of the matter. Your quoted fee for each phase will be fixed and agreed in writing before work begins. We do not charge a percentage of tax savings or reductions.

Client Experiences

What clients say after the matter is resolved.

These testimonials reflect individual client experiences. Prior results do not guarantee a similar outcome in any other matter.

"I received a CP504 on a Friday afternoon and called Ledgerwood that evening. By Monday morning we had a plan. Graham knew exactly what the IRS would and would not accept, and the levy was released before it ever hit my accounts. I wish I had called six months earlier."

R. Valenzuela Collections defense — Scottsdale business owner

"Every tax relief company I called promised me they could settle for pennies on the dollar. Ledgerwood told me honestly whether I actually qualified for an offer in compromise before taking my money. I did qualify — and they handled every step. No surprises, flat fee, done."

D. Harrington Offer in compromise — Tempe resident

"The audit started as a routine correspondence audit and then the agent asked for a meeting. Elena stepped in immediately and handled every communication from that point forward. The final assessment was less than half of what the IRS originally proposed."

M. Thornton Audit representation — Phoenix contractor

What is the difference between a tax attorney and a tax resolution company?

Tax resolution companies are not law firms. Their representatives — often enrolled agents or non-attorney staff — cannot assert attorney-client privilege, and their promises of settling for "pennies on the dollar" are subject to regulation by the FTC because many of them are false or misleading. A tax attorney is licensed by the state bar, bound by professional conduct rules, and holds the only privilege that protects your communications from the IRS in both civil and criminal matters. The fee structures are often comparable; the protection is not.

How quickly do I need to respond to an IRS notice?

It depends on the notice type. Most balance-due notices (CP14) request payment within 30 days. CP2000 proposed adjustments allow 60 days to respond. Final notices of intent to levy (LT11, Letter 1058) give you 30 days to request a Collection Due Process hearing before the IRS can seize assets — and this deadline cannot be extended. Check the specific deadline on your letter and contact us the same day you receive it. Earlier is always better; some deadlines, once missed, permanently forfeit rights.

Do I actually qualify for an Offer in Compromise?

Fewer people qualify than the commercials suggest. The IRS calculates your "reasonable collection potential" — essentially the present value of future income plus net realizable value of assets — and will not accept an offer for less than that number. Qualification requires that your income and assets genuinely cannot cover the liability within the remaining collection statute period. We conduct the financial analysis before recommending an offer, and we will tell you honestly if another option — an installment agreement, currently not collectible status, or penalty abatement — is more realistic for your situation.

What happens if I just ignore the IRS letters?

The IRS has extraordinary collection powers it can exercise without going to court. Ignoring notices leads, in sequence, to: a federal tax lien filing (which becomes public record and damages credit), bank levies that sweep your entire account balance, wage garnishment (which the IRS can sustain indefinitely), and seizure of physical assets including vehicles and real estate. Unlike private creditors, the IRS does not need a judgment to garnish wages or levy a bank account. The collection process moves faster than most people expect, and the consequences of inaction compound at interest.

Is my initial consultation really confidential?

Yes. The attorney-client privilege attaches from the first conversation when you are consulting an attorney for legal advice, even before an engagement agreement is signed. Nothing you tell us in a consultation can be disclosed to the IRS, to any other party, or in any proceeding without your consent. We also recommend that you not send tax documents, account statements, or other sensitive records through the contact form on this site until a formal engagement is in place — not because we would disclose them, but because unencrypted email is not a secure channel.

Can you help with both the IRS and Arizona Department of Revenue at the same time?

Yes. State and federal tax disputes often run in parallel — an IRS income tax audit frequently triggers an Arizona audit of the same year, and a federal payroll tax problem often has an Arizona TPT component. We coordinate representation across both agencies and ensure that positions taken in one proceeding do not create inadvertent admissions in the other. Elena Navarro leads our Arizona Department of Revenue practice and has appeared before the Arizona Office of Administrative Hearings and the Arizona Tax Court.

What if I have unfiled returns from multiple years?

Multiple unfiled years are common and are not an insurmountable problem. The IRS requires that you be in filing compliance — or have a plan to become compliant — before it will approve any resolution agreement, including an installment agreement or offer in compromise. We work with you to reconstruct the necessary financial records, prepare the delinquent returns, and negotiate penalty abatement for the failure-to-file and failure-to-pay penalties simultaneously with the underlying liability. The process has a defined sequence, and we manage every step of it.

Confidential — No Charge

Begin with a confidential consultation.

The attorney-client privilege begins with this conversation. Tell us what the IRS has sent you or what you are concerned about, and we will respond with an honest assessment of your situation and your options. There is no cost for the initial consultation and no obligation to proceed.

Do not send tax documents, account numbers, or sensitive financial records through this form. The form is not a secure channel. We will establish a secure method for document exchange once an engagement is in place.

7150 E. Camelback Road, Suite 444
Scottsdale, AZ 85251 480-555-0182

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