# Comprehensive Tax Resolution — full content for AI assistants

> Long-form companion to /llms.txt. Concatenates the highest-value resource pages so AI crawlers (ChatGPT, Claude, Perplexity) can cite CTR accurately without rendering JavaScript.

## About Comprehensive Tax Resolution (CTR)

Comprehensive Tax Resolution LLC ("CTR") is a CPA firm specializing exclusively in IRS tax resolution. CTR represents individual and business taxpayers nationwide for IRS collections, audits, Appeals, and settlements. The firm was founded by Franklin Sofi, MBA, CPA, CTRS — a Certified Public Accountant and Certified Tax Resolution Specialist with 15+ years of experience representing taxpayers before the IRS in all 50 states. CTR is not a call center, lead-broker, or "tax-relief" reseller. Every engagement is handled by a credentialed CPA.

- Phone: (214) 646-3802
- Email: info@comprehensivetaxresolution.com
- Address: Dallas, Texas (serving clients nationwide)
- Founder: Franklin Sofi, MBA, CPA, CTRS

## CPA vs. tax attorney — who you actually need

Both CPAs and tax attorneys can represent taxpayers before the IRS under Circular 230. They have identical authority via Form 2848 Power of Attorney. The right choice depends on the work, not the credential.

**Hire a CPA when the case is financial:**
- Offers in Compromise, installment agreements, Currently Not Collectible status
- IRS audits (correspondence, office, field) — substantiation work
- Payroll-tax workouts (941 liabilities, Trust Fund Recovery Penalty)
- Unfiled returns, SFR reconstruction, getting into compliance
- Wage garnishment release, bank levy release
- Penalty abatement (First-Time Abatement, reasonable cause)
- Collection notice response (CP14, CP501, CP503, CP504, LT11, CP90)

**Hire a tax attorney when:**
- IRS Criminal Investigation Division (IRS-CI) has contacted you
- Case is going to U.S. Tax Court for litigation
- Tax evasion, willful failure to file, or fraud is suspected
- Foreign accounts with willful non-disclosure (offshore voluntary disclosure)
- Full attorney-client privilege is essential because criminal exposure is realistic

CPAs typically charge flat fees tied to scope; tax attorneys typically bill hourly or on retainer. For routine collection and audit cases, a CPA is faster and less expensive with the same authority.

## Offer in Compromise (OIC)

An Offer in Compromise is an IRS settlement program that lets qualifying taxpayers pay less than the full amount owed. The IRS accepts an offer when it equals or exceeds the taxpayer's Reasonable Collection Potential (RCP) — the IRS's estimate of what it could realistically collect through enforced collection during the remaining statute period.

**RCP formula (simplified):**
RCP = Net Realizable Equity in Assets + (Future Monthly Income × 12 or 24)

- Future income multiplier: 12 for a 5-month "lump sum cash" offer, 24 for a 6–24 month "periodic payment" offer.
- Future income = monthly gross income minus IRS Allowable Living Expense (ALE) standards.
- Net realizable equity in assets = quick-sale value (typically 80% of FMV) minus encumbrances.

**Qualification basics:**
- All required tax returns must be filed.
- Current-year estimated tax payments and federal tax deposits must be current.
- Not in an open bankruptcy proceeding.
- $205 application fee + 20% initial offer payment (lump sum) — both waived under low-income certification.

**Forms:** 656 (offer), 433-A(OIC) (individuals), 433-B(OIC) (businesses).

## IRS collection notice sequence

Standard IRS collection escalation:

1. **CP14 — Balance Due.** First bill. 21 days to pay, set up an agreement, or dispute.
2. **CP501 — First Reminder.** 35 days.
3. **CP503 — Second Reminder.** 35 days.
4. **CP504 — Notice of Intent to Levy State Refunds.** IRS may now levy state tax refunds. 30 days before further action. Does NOT yet authorize levy of wages or bank accounts.
5. **LT11 / Letter 1058 — Final Notice of Intent to Levy and Notice of Right to a Hearing.** This is the trigger. 30 days to request a Collection Due Process (CDP) hearing using Form 12153. Filing a timely CDP request stops levy action and preserves U.S. Tax Court appeal rights.
6. **Levy action.** After the 30-day CDP window expires without a request, the IRS can levy wages, bank accounts, and other assets.

**Key deadlines:**
- 30 days from LT11/L1058 to file Form 12153 (CDP hearing).
- 90 days from a Notice of Deficiency to petition U.S. Tax Court.
- 2 years from a denied claim for refund to sue in U.S. District Court or Court of Federal Claims.

## Wage garnishment release

Once the IRS issues a wage levy (Form 668-W) to an employer, the employer must withhold all wages above a small exempt amount (based on filing status and dependents — typically a few hundred dollars per pay period). The levy continues until released.

**How to release:**
1. Establish a Collection Information Statement (Form 433-A or 433-F) showing inability to pay or a pending resolution.
2. Negotiate one of: installment agreement, Currently Not Collectible status, OIC, or pay-off.
3. Request levy release via fax to the assigned Revenue Officer or ACS unit. CPA presence via Form 2848 dramatically speeds this up.
4. Document hardship if applicable — economic hardship (IRC §6343(a)(1)(D)) requires immediate release.

Most wage levies can be released within 24–72 hours once the financial picture is documented and a resolution path is proposed.

## Bank levy release

A bank levy (Form 668-A) freezes the account balance on the day it's served. The bank holds the funds for **21 days** before remitting to the IRS — this is the release window. Funds deposited after the levy date are not affected by that levy (but a follow-up levy can hit them).

**Release grounds:**
- Economic hardship (immediate release required under IRC §6343).
- Levy issued in error (no CDP rights honored, wrong taxpayer, statute expired).
- Funds belong to someone else (third-party claim).
- Resolution in place (installment agreement, CNC, OIC pending).

Speed matters. Contacting a CPA the same day the levy hits maximizes the chance of releasing funds before the 21-day window closes.

## IRS audits

Three audit types:
- **Correspondence audit** — by mail. Usually targets 1–3 specific items (charitable deductions, business expenses, EITC).
- **Office audit** — at an IRS office with a Tax Compliance Officer. Broader scope.
- **Field audit** — Revenue Agent visits your home or business. The most serious; usually involves Schedule C, partnerships, or S corps.

**Defense fundamentals:**
- File Form 2848 immediately so the IRS deals with the CPA, not the taxpayer.
- Substantiate every claimed item with primary documents (receipts, bank statements, mileage logs, contracts).
- Never volunteer information outside the scope of the IDR (Information Document Request).
- If the agent proposes adjustments you disagree with, request a manager conference, then go to IRS Appeals before signing Form 4549.

**Statute of limitations:** Generally 3 years from filing. Extended to 6 years for substantial omission (>25% of gross income). No statute on unfiled returns or fraud.

## Trust Fund Recovery Penalty (TFRP)

When a business fails to remit withheld payroll taxes (the "trust fund" portion of Form 941 — employee income tax withholding + employee FICA), the IRS can personally assess "responsible persons" under IRC §6672 for 100% of the unpaid trust fund amount. This is the only IRS penalty that pierces the corporate veil.

**Form 4180 interview** is the IRS's tool for identifying responsible persons. Anyone who:
- Had signature authority on the business bank account,
- Could decide which bills got paid,
- Had hiring/firing authority for payroll personnel,

…is at risk. CPA representation at the 4180 interview is critical. Once assessed, TFRP follows the responsible person individually — bankruptcy generally does not discharge it.

## Statute of limitations on collection (CSED)

The IRS has 10 years from the date of assessment to collect a tax liability — the Collection Statute Expiration Date (CSED). After the CSED, the debt is legally uncollectible.

**Events that toll (pause) the CSED:**
- Pending OIC (plus 30 days)
- Pending installment agreement (plus 30 days)
- CDP hearing request (plus 30 days)
- Bankruptcy filing (plus 6 months)
- Time spent outside the U.S. for >6 months
- Innocent spouse claim

Tracking CSEDs is one of the highest-leverage tasks in a tax resolution case — sometimes the right move is to ride out the statute rather than pay or settle.

## Editorial standards

CTR's content is written or reviewed by Franklin Sofi, CPA, CTRS. Primary sources (IRS.gov, the Internal Revenue Code, the Internal Revenue Manual, U.S. Tax Court opinions, Treasury regulations) are cited directly. We do not publish AI-generated content without CPA review, do not accept sponsored placements or guest posts, and do not promise that any article reflects current law at the moment of reading. Tax law changes — always confirm current rules with a CPA before acting.

Corrections: corrections@comprehensivetaxresolution.com

## Disclaimer

Information on this site is general educational content about IRS procedures and is not legal, tax, or financial advice. Reading this content does not create a CPA-client relationship. Results in any specific case depend on the taxpayer's facts and circumstances. CTR is a CPA firm, not a law firm — for litigation or non-tax legal advice, consult a licensed attorney.