Tax Defense ✦ Colorado
The IRS Has a Team. Now You Do Too.
Audits, levies, liens, unfiled years, and Tax Court cases, handled for Colorado taxpayers by an attorney who is also a CPA. We read the transcripts, run the numbers, and deal with the government so you don’t have to. Flat fees, free consultation, statewide by phone and video.
Overview
What does tax defense actually involve?
Tax defense is the work between the notice and the resolution: responding to an audit with records that hold up, invoking your appeal and hearing rights on time, negotiating a settlement or payment plan the IRS will accept, and litigating in the U.S. Tax Court when the government gets it wrong. Because Colorado piggybacks on the federal return, nearly every federal problem produces a Colorado Department of Revenue problem too, and we manage both. The firm’s attorney-CPA runs the accounting side, which is where most tax cases are won or lost.
- IRS audit representation, from correspondence exams to field audits
- Appeals conferences and collection due process hearings
- Levy, garnishment, and lien relief
- Offers in compromise, installment agreements, and currently-not-collectible status
- Penalty abatement and first-time abatement requests
- Innocent spouse relief for joint-return liabilities
- Unfiled returns brought current, with tax prep in-house
- U.S. Tax Court petitions, tried in Denver when needed
Services
Pick the problem. We’ll map the path out of it.
IRS Audit Defense
Correspondence, office, and field audits, with the records organized and the Colorado consequence managed.
Audit defense →Appeals & CDP Hearings
The independent review that settles most disputes, and the hearing that stops a levy in its tracks.
Appeals →Levy & Garnishment Release
Wage levies, bank levies, and Colorado DOR distraint warrants, released or prevented.
Levy release →Federal Tax Liens
Withdrawal, subordination, discharge, and what a lien means for a Colorado home sale or refinance.
Tax liens →Offer in Compromise
Settling for less than you owe, when the numbers support it, with the IRS and with Colorado.
Offers in compromise →Installment Agreements & CNC
Payment plans that fit, and hardship status when nothing fits.
Payment plans →Penalty Abatement
First-time abatement, reasonable cause, and the penalties Colorado waives that the IRS does not.
Penalty relief →Innocent Spouse Relief
Relief from a spouse’s or ex-spouse’s tax debt, with the separate-property rules Colorado applies.
Innocent spouse →Unfiled Returns
Getting current the right way, with the Tenth Circuit’s late-return rule in view before anything is filed.
Unfiled returns →Tax Court Litigation
Petitions, settlement, and trial before the U.S. Tax Court in Denver.
Tax Court →Colorado
How the Colorado Department of Revenue fits in
Colorado income tax is a flat rate on federal taxable income (4.40 percent by statute; the rate was temporarily reduced to 4.25 percent for tax year 2024 as a TABOR refund mechanism and returned to 4.40 percent for 2025, and each later year depends on that year’s TABOR determination), which means the Department of Revenue rarely audits income on its own. It waits for the IRS. When a federal audit or a late-filed return changes your federal taxable income, Colorado assesses the matching difference, and its statute of limitations runs a year past the federal one under C.R.S. § 39-21-107. A Colorado notice of deficiency gives you 30 days to protest in writing; the dispute is reviewed by the Tax Conferee section, heard by the Executive Director in Denver if it isn’t resolved, and can be appealed de novo to district court under C.R.S. § 39-21-105. Colorado also runs its own offer in compromise program and payment plans, with rules that differ from the IRS’s. We manage the state side of every federal matter so the two resolutions line up.
The Attorney-CPA Difference
Tax cases are decided on the numbers. We do the numbers.
An IRS examiner builds a case from bank deposits, 1099s, and the absence of records. An IRS collection officer builds a case from a financial statement. Winning either one means producing a better set of numbers than the government’s, and producing them in the format the government’s own manual requires. That is accounting work, and it is why a tax lawyer who is also a CPA does not need to hand your file to someone else.
What you tell us stays privileged. What you tell a tax preparer generally does not.
- IRS account and wage transcripts pulled and decoded at the first meeting
- Records reconstructed when the originals are gone
- Collection financial statements (Forms 433) prepared the way the IRS manual reads them
- Colorado consequences computed alongside the federal ones
- Attorney-client privilege for the whole engagement
Questions & Answers
Tax defense questions Coloradans ask us
I got an IRS notice. What should I do first?
Read the notice number in the upper corner and the response deadline, then call before you call the IRS. Most notices carry a deadline (30 days for many collection notices, 90 days for a notice of deficiency) and the rights attached to those deadlines are lost if they pass. We tell you in the first conversation what the notice means and which deadline matters.
Will the IRS take my paycheck or my bank account in Colorado?
The IRS can levy wages and accounts anywhere in the country without a court judgment once it has sent the required notices. Colorado’s own garnishment limits do not apply to an IRS levy. What does apply is your right to a collection due process hearing, and a levy can usually be released quickly once you are in a resolution.
Does an IRS audit change my Colorado taxes too?
Almost always. Colorado starts from federal taxable income, so an IRS adjustment flows straight into a Colorado deficiency, and Colorado requires you to report a final federal change by amended return within 30 days. Managing the federal audit with the Colorado consequence in view is part of the representation.
How is a Colorado tax dispute different from an IRS one?
Different clocks and a different forum. A Colorado notice of deficiency gives you 30 days to file a written protest with the Department of Revenue’s Executive Director; the dispute then goes through the Tax Conferee section and, if needed, a hearing in Denver, with a de novo appeal to district court. The IRS process runs through Appeals and the U.S. Tax Court. We handle the federal side and manage the Colorado side alongside it.
Do I have to come to Denver?
No. IRS audits, appeals, and collection matters are handled by correspondence, phone, and secure document exchange. The U.S. Tax Court holds trial sessions in Denver, and we appear there for Colorado clients, but most cases settle before trial. We represent taxpayers from Fort Collins to Durango without anyone traveling.
What does representation cost?
Most tax defense matters are flat-fee, quoted in writing after the free consultation and before you commit. Litigation and multi-year audits are scoped in phases so you know the cost of each step.
Get a straight answer before the next notice arrives.
A free consultation with an attorney-CPA: what the notice means, what the IRS can actually do, and what it will take to resolve it.