Federal Tax Lawyers

Tax Resolution: Addressing IRS Problems Before They Grow

Tax problems rarely resolve themselves. What begins as an unopened notice can become a lien, a levy, or a garnishment — often faster than most people expect. At Frazier Law, we work with individuals and business owners who are dealing with IRS collection matters, unfiled returns, disputed assessments, or unresolved balances that have been sitting too long.

Our approach is methodical and calm. We begin by understanding exactly where things stand — what the IRS knows, what you owe, and what options are available under current law. From there, we build a strategy tailored to your specific circumstances, not a one-size-fits-all solution.

Charles Frazier’s background as a former IRS Revenue Agent gives Frazier Law a perspective that most tax attorneys simply don’t have. He knows how cases are assigned, how agents prioritize their workloads, how collection actions are initiated, and where the legitimate pressure points exist for negotiation. That knowledge directly benefits clients working through difficult tax situations.

Common Tax Resolution Matters We Handle

The clients we help most often are dealing with one or more of the following:

• IRS audits — correspondence, office, and field examinations
• Unfiled federal or state tax returns (often multiple years)
• Tax liens affecting credit, real property, or business operations
• IRS levies on wages, bank accounts, or receivables
• Penalty abatement requests based on reasonable cause or first-time penalty abatement
• Offers in Compromise, when a negotiated settlement is a viable option
• Installment agreements structured to protect income and assets
• Currently Not Collectible status for clients who cannot pay
• Trust Fund Recovery Penalty assessments against business owners and responsible parties
• Innocent or Injured Spouse Relief

High-Income Earners and Business Owners Face Distinct Risks

The IRS’s enforcement resources are not distributed evenly. High-income earners and business owners are disproportionately represented in audits, particularly those involving pass-through entities, real estate investments, self-employment income, or significant itemized deductions. The complexity of a high-income tax return creates more surface area for scrutiny — and more need for thoughtful representation when questions arise.

For business owners, the stakes are compounded. An unresolved tax matter doesn’t just affect personal finances — it can cloud a business sale, complicate a financing application, or surface at the worst possible moment during a transition. Resolving these matters proactively, while options remain available, is almost always the better path.

We frequently work with clients in Murfreesboro, Nashville, Franklin, and Rutherford County, Tennessee, as well as Midland and Saginaw, Michigan, who have reached a point in their professional or financial lives where getting these matters resolved — quietly and completely — is simply the right next step.

IRS Audit Representation: Navigating Examinations With Confidence

Receiving an IRS audit notice is unsettling, even for financially responsible individuals and well-organized businesses. The examination process can feel opaque, and the stakes — both financial and psychological — are real. Experienced representation helps level the playing field.

Frazier Law represents individuals and businesses at all stages of the IRS examination process, from initial correspondence audits to complex field examinations conducted by IRS Revenue Agents. Our goal in every engagement is the same: ensure that the IRS has only what it needs, that your legal rights are preserved, and that the examination concludes with the best possible outcome given the facts.

Types of IRS Audits

Not all audits are the same. The IRS uses several examination methods depending on the complexity of the return and the nature of the inquiry.

Correspondence audits are the most common. The IRS sends a letter requesting documentation for a specific item — a deduction, a credit, or reported income. These are often handled entirely by mail, and with proper documentation, they can be resolved without escalation. However, failing to respond, or responding without understanding what the IRS is actually asking, can turn a manageable situation into a more significant problem.

Office audits involve an in-person meeting at an IRS office. These are more involved and typically cover multiple issues. Preparation is essential. Knowing what to bring, what not to bring, and how to present your records makes a meaningful difference in how the examination unfolds.

Field audits are the most comprehensive. An IRS Revenue Agent — the same type of agent Charles Frazier once was — visits your home, business, or the office of your representative. These examinations often span multiple tax years and can touch on complex issues involving business income, self-employment, real estate, or closely held entities. Having experienced legal and tax counsel present from the beginning is critical.

What Triggers an IRS Audit?

While no return is immune from examination, certain patterns consistently draw IRS attention. High-income filers are statistically more likely to be audited. Returns reporting significant Schedule C self-employment income, large charitable contribution deductions, rental losses, home office deductions, or substantial business meals and travel expenses are among the profiles that receive closer review.

Pass-through entities — S corporations, partnerships, and LLCs taxed as partnerships — have received increased IRS scrutiny in recent years, particularly those with significant income flowing to owners in ways that minimize self-employment tax exposure. Business owners with complex returns involving multiple entities, intercompany transactions, or unusual income patterns should maintain strong documentation and understand their exposure before an inquiry begins.

We work with clients throughout Tennessee and Michigan who want to understand their audit risk as part of ongoing tax planning — not just after a notice arrives.

Tax Liens and Levies: Understanding IRS Collection Actions

When a tax liability goes unresolved, the IRS has significant collection authority. Understanding the distinction between a tax lien and a tax levy — and knowing when each may be used — is important for anyone navigating an unresolved balance.

A federal tax lien is a legal claim the IRS places against your property when you owe a tax debt that has not been resolved. The lien attaches to all of your assets — real property, financial accounts, business assets, and future assets acquired during the lien period. A Notice of Federal Tax Lien may be filed publicly, which can affect credit, complicate real estate transactions, and create challenges with lenders and business partners.

A tax levy is an actual seizure of property. Where a lien is a claim, a levy is the enforcement of that claim. The IRS may levy bank accounts, garnish wages, seize accounts receivable, or, in more serious cases, take physical property. For business owners, a levy on operating accounts or receivables can create immediate cash flow disruption.

These actions do not happen without warning. The IRS is required to follow a series of procedural steps before initiating a levy, including issuing a Final Notice of Intent to Levy and providing appeal rights. However, the window to respond is limited, and inaction during that period can significantly narrow your options.

Resolving or Preventing Collection Actions

There are established pathways for addressing liens and levies, and the right approach depends on your specific circumstances. Common strategies include:

• Requesting a Collection Due Process (CDP) hearing to preserve appeal rights and explore resolution options
• Negotiating a lien discharge or subordination to facilitate a property sale or refinancing
• Seeking a lien withdrawal after the underlying liability is resolved
• Establishing an installment agreement or other resolution that stops active levy action
• Demonstrating financial hardship to qualify for Currently Not Collectible status

We work with clients who are dealing with active collection matters and those who simply want to understand their exposure before something escalates. For clients in Murfreesboro, Nashville, and the surrounding Rutherford County communities, as well as those we serve in Midland and Saginaw, early engagement with experienced counsel is consistently the most effective path forward.

Offers in Compromise: When Settlement Is a Viable Option

An Offer in Compromise (OIC) allows eligible taxpayers to settle a federal tax liability for less than the full amount owed. It is one of the most discussed — and most misunderstood — tools in tax resolution. The IRS accepts Offers in Compromise selectively, based on a detailed analysis of the taxpayer’s ability to pay, income, expenses, and asset equity.

For the right client, an OIC can provide meaningful relief. But it is not a universal solution, and the IRS rejects a significant percentage of the offers it receives. Applications require complete financial disclosure, careful documentation, and a realistic assessment of what the IRS calculates as a taxpayer’s Reasonable Collection Potential (RCP). Submitting an offer that does not align with that calculation is unlikely to succeed and may delay other resolution options.

Before recommending an OIC, we conduct a thorough analysis of the client’s financial situation. If the numbers support an offer, we prepare the application carefully and negotiate with the IRS in a way that gives the submission the best possible chance of acceptance. If other resolution pathways are more appropriate, we say so directly.

Who May Qualify

Candidates for an Offer in Compromise generally share certain characteristics: the liability is substantial, the ability to pay the full amount within the remaining collection period is genuinely limited, and full financial disclosure will support that conclusion. High-income earners whose financial circumstances have changed significantly — due to business failure, market losses, health events, or structural changes in income — are among those who may qualify even if their income profile looks strong on paper.

There are also alternatives worth evaluating, including penalty abatement, installment agreements, and Currently Not Collectible status, each of which may be more appropriate depending on the circumstances. Our role is to identify the path that provides the most durable resolution, not simply the one that sounds most appealing.

Strategic Tax Planning: The Quiet Discipline That Protects What You’ve Built

Most tax problems are not inevitable. They develop over time, often from the same sources: decisions made without adequate counsel, structures that were not reviewed as circumstances changed, and a general tendency to address tax planning reactively rather than proactively.

Strategic tax planning is the practice of organizing your financial affairs in a way that is legally compliant, tax-efficient, and aligned with your long-term goals. For high-income earners and business owners, this means looking beyond the current tax year and thinking about how income is characterized, how assets are held, how business structures affect tax exposure, and how compensation strategies interact with retirement planning and wealth transfer.

At Frazier Law, tax planning is not a product we sell. It is a discipline we bring to every client relationship. The combination of legal counsel, CPA expertise, and financial planning credentials — including the CFP® and ChFC® designations held by Charles Frazier — allows us to analyze planning questions from multiple angles and identify strategies that are both effective and defensible.

Tax Planning for Business Owners

Business owners carry a more complex tax burden than most. Beyond personal income tax, they must navigate self-employment taxes, payroll obligations, entity-level taxation, depreciation and cost recovery decisions, and the tax treatment of business-related expenses. Each of these areas presents both risk and opportunity.

Common planning opportunities for business owners include entity structure optimization (choosing the right form of organization and revisiting that choice as the business grows), qualified business income deduction planning under Section 199A, retirement plan design and contribution strategies, compensation planning for owner-employees, and the timing of income and deductions across tax years.

Business owners in Rutherford County and the broader Nashville region, as well as those we work with in Midland and Saginaw, often come to us after years of relying on tax preparation alone — without the forward-looking planning that would have reduced their tax burden materially. The difference between preparation and planning is significant, and for most business owners, the return on proactive planning is substantial.

Tax Planning for High-Income Earners

High-income individuals face a tax environment defined by layered complexity: the net investment income tax, the additional Medicare tax on earned income, phase-outs of deductions and credits, alternative minimum tax exposure in certain situations, and the challenge of managing capital gains alongside ordinary income.

Effective planning at this income level requires coordinating across multiple dimensions — investment accounts, retirement assets, real estate, business interests, and family financial planning. We work with clients and their existing advisors to identify and implement planning strategies that reduce unnecessary tax exposure without creating compliance risk.

For clients approaching significant liquidity events — a business sale, a real estate transaction, or the exercise of equity compensation — advance planning can produce meaningfully different tax outcomes than after-the-fact strategies. The earlier the conversation begins, the more options remain available.

Business Formation and Structure: Getting It Right From the Start

The decisions made when forming a business — or when revisiting an existing structure as the business grows — have lasting tax and legal consequences. Entity type, ownership structure, compensation arrangements, and the allocation of profits and losses all affect how the business is taxed and how owners are protected.

Frazier Law counsels new and established business owners on entity selection, formation planning, and ongoing structural review. Our approach integrates legal and tax analysis, so the advice you receive reflects both the legal implications of your structure and its tax efficiency across the life of the business.

For entrepreneurs and business owners in Tennessee and Michigan, the stakes of getting formation right are significant. A poorly structured entity can result in unnecessary self-employment tax exposure, missed deduction opportunities, personal liability risk, and complications when it comes time to bring in partners, raise capital, or transition the business. We help clients think through these issues at the outset — and help established owners revisit them when their circumstances change.

Common Formation and Structure Considerations

• Entity type selection: sole proprietorship, partnership, LLC, S corporation, or C corporation
• Tax classification elections and their long-term implications
• Owner compensation strategies and their effect on self-employment and payroll taxes
• Multi-entity structures for businesses with distinct activities or assets
• Buy-sell agreements and ownership transfer planning
• Exit and succession planning considerations built into the formation structure

Why Clients and Advisors Choose Frazier Law

The clients who work with us are typically not looking for a firm that will simply process their matter. They are looking for experienced, thoughtful counsel from professionals who understand complexity and can navigate it efficiently.

Frazier Law brings together a rare combination of credentials and experience. Principal Attorney Charles Frazier holds a JD, a Master of Taxation, and an LLM in Taxation, along with the CFP®, ChFC®, and RICP® designations and board certification as an Estate Planning Law Specialist. He is a former IRS Revenue Agent and a U.S. Army Ranger — two backgrounds that share a common discipline: understanding the rules of engagement and operating effectively within them.

Rick Miller, CPA, contributes deep accounting and tax expertise that complements the legal practice. Together, they provide a level of integrated analysis that allows the firm to address the full range of tax resolution and planning needs — without requiring clients to coordinate across multiple unconnected advisors.

We also work closely with CPAs, financial advisors, and attorneys who refer clients to us. For trusted advisors in Tennessee and Michigan, Frazier Law provides a resource they can rely on when a client’s situation requires legal depth and tax experience beyond the scope of their own practice.

“We’re always happy to help think these situations through. Whether you’re a client facing a tax matter or a trusted advisor supporting someone who is, we welcome the opportunity to be a resource.”   — Frazier Law

Recent Cases

$3,921,685 — Reduction of Tax, Penalties & Interest
$1,610,015 — Taxes, Penalties & Interest Not Collectable
$1,041,258 — Tax Adjustment From Contested Audit

*Past results are not guaranteed and differ on a case-by-case basis.

Contact Us Today

At Frazier Law, we work with individuals and businesses who need experienced legal and tax counsel — whether that means resolving an active IRS matter, developing a forward-looking tax strategy, or simply getting a clear picture of where things stand.

We serve clients in Tennessee, Michigan, and Texas, with particular depth in the communities of Murfreesboro, Nashville, Franklin, and Rutherford County, as well as Midland and Saginaw in Michigan. Trusted advisors across these regions rely on us when a client’s situation calls for specialized expertise.

If you’re facing a tax matter — or simply want to be better positioned going forward — we welcome the opportunity to be helpful. The first conversation is a good place to start.