IRS Tax Lawyer Amelia Island, FL
If you have received a notice from the Internal Revenue Service, retaining legal guidance promptly is essential. Every letter, from a routine examination notice to a final notice of intent to levy, carries a strict deadline. By consulting attorneys early, there is more time to collect evidence and build a defense strategy.
Crepeau Mourges represents individuals, businesses, and fiduciaries in the full range of federal tax controversies. Our founding partners are dual-credentialed in tax law and accounting, which allows our Amelia Island, FL IRS tax lawyer to evaluate both the legal position and the financial records that drive it. Schedule a free consultation today to discuss your tax matter.
Why Choose Crepeau Mourges as Your IRS Tax Lawyer in Amelia Island, FL?
Dual Credentials in Tax Law and Accounting
Our founding partners bring legal and accounting training to every federal tax matter. Brian J. Crepeau earned a B.S. in Management Science-Accounting from Bridgewater State University in 1997 and a J.D. from American University, Washington College of Law in 2003.
Brandon N. Mourges holds an LL.M. in Taxation from the University of Baltimore School of Law and a B.S. in Economics from The Wharton School at the University of Pennsylvania. Brandon is a member of the American Association of Attorney-CPAs, the Maryland Association of Certified Public Accountants, and the Federal Bar Association.
Clients engaging a tax lawyer in Amelia Island, FL at Crepeau Mourges receive that combined training on every matter.
Focused Federal Tax Controversy Practice
Our team brings more than four decades of combined experience in federal tax controversy. We represent taxpayers in IRS audits, administrative appeals, collection due process hearings, U.S. Tax Court litigation, and criminal tax investigations. Brian focuses on individual and corporate tax disputes and on matters involving brokers, financial planners, and investment advisers. Brandon represents individuals and businesses in complex financial matters, including cases at the border of tax and white-collar criminal law.
Recognition and Pro Bono Work
Brandon has been named a Rising Star by Super Lawyers, listed on Benchmark Litigation’s “40 & Under Hot List,” and selected as JD Supra’s Readers’ Choice Top Author in tax for 2020. He received the J. Ronald Shiff Memorial Pro Bono Award from the Maryland State Bar Association in 2015 for volunteer work with the Fort Meade Volunteer Income Tax Assistance program.
What Our Clients Say
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“I’ve been quite satisfied with Attorney Crepeau and his team in working to resolve my federal tax liability matters. He’s thorough and responsive, which is always a plus when it comes to serious legal issues.” – Zeni Ronyag
Read more reviews on our Google Business Profile.
Types of IRS Matters We Handle for Amelia Island Clients
Our federal tax practice covers the following categories of IRS representation:
- IRS audits and examinations. Field audits, office audits, and correspondence audits for individuals, businesses, and fiduciaries, from the opening notice through closing agreement or Appeals.
- IRS appeals. Protests and representation before the IRS Independent Office of Appeals, including docketed and non-docketed cases.
- U.S. Tax Court litigation. Petitions filed in response to statutory notices of deficiency, small-case and regular proceedings, and related motions practice.
- IRS collection matters. Offers in compromise, installment agreements, currently-not-collectible status, penalty abatement, and innocent spouse relief.
- Tax liens and levies. Lien withdrawals, subordinations, and discharges, along with levy releases and collection due process hearings.
- Unfiled returns. Structured catch-up filings for clients with multiple years of unfiled tax returns, coordinated to address both civil liability and any criminal exposure.
- Criminal tax investigations. Representation during IRS Criminal Investigation inquiries, including eggshell audits and grand jury matters.
- Offshore compliance. FBAR, FATCA, streamlined filing procedures, and the IRS Voluntary Disclosure Program for clients with unreported offshore assets.
- Employment tax and trust fund recovery penalty. Defense of assessments under IRC § 6672 against owners and responsible persons.
Federal Legal Requirements for IRS Tax Representation
Federal tax practice is governed primarily by the Internal Revenue Code (Title 26) and the Treasury Regulations. Procedural rules for practice before the IRS are set out in IRS Circular 230, which authorizes attorneys, CPAs, and enrolled agents to represent taxpayers before the agency.
Several deadlines drive almost every IRS matter. A statutory notice of deficiency triggers a 90-day window to file a petition in U.S. Tax Court under IRC § 6213, and that deadline is jurisdictional. A final notice of intent to levy triggers a 30-day window to request a collection due process hearing under IRC § 6330. The general statute of limitations on assessment is three years under IRC § 6501, extended to six years for substantial omissions of income and indefinite where tax fraud or a failure to file is established.
Florida has no personal income tax, which means most federal tax matters for Amelia Island residents are handled without a parallel state income tax proceeding. Corporate taxpayers in Florida remain subject to state corporate income tax under Chapter 220 of the Florida Statutes, administered by the Florida Department of Revenue, which sometimes runs alongside a federal examination.
Key Components of an IRS Tax Case in Amelia Island
The Notice and the Deadline
Every IRS matter begins with a specific notice, and nearly every notice carries a specific response deadline. Identifying which notice you have received, and calendaring the corresponding deadline, is the first step in any representation. Missed deadlines can foreclose rights that would otherwise be available, including the right to petition the Tax Court before paying the asserted liability.
Records and Return Analysis
Before any position is taken with the IRS, the underlying records should be reviewed in detail. Returns, schedules, bank records, third-party information returns, and the books that support them often determine whether a proposed adjustment is correct, partially correct, or wrong. That review is faster and more thorough when conducted by counsel with accounting training.
Appeals Posture
Most IRS disputes are resolved short of litigation, often through the IRS Independent Office of Appeals. Tax appeals evaluate the hazards of litigation and can settle on terms unavailable at the examination level. Preserving the right to Appeals, and presenting a record that supports a favorable settlement, requires planning from the opening of the audit.
Penalty Exposure
Civil penalties range from accuracy-related additions at 20 percent under IRC § 6662 to civil fraud penalties at 75 percent of the underpayment under IRC § 6663. Information return penalties, failure-to-file penalties, and failure-to-pay penalties can also apply. Abatement arguments depend on the specific facts of each case and on the reasonable cause and first-time abatement standards applied under IRS procedures.
Criminal Exposure
Not every IRS audit carries criminal risk, but some do. Method-of-proof indicators, large unexplained deposits, and patterns of unreported income can move a civil examination toward IRS Criminal Investigation. Early recognition of those indicators, along with careful structuring of communications, is one of the most consequential decisions in any federal tax matter.
Collection Resolution
Once a liability is established, collection options include offers in compromise, partial-pay installment agreements, currently-not-collectible status, and, in limited cases, discharge in bankruptcy. Each option carries eligibility requirements and strategic trade-offs that should be evaluated against the taxpayer’s full financial picture.
Contact Crepeau Mourges
If the IRS has contacted you about an audit, an unpaid balance, a lien, a levy, or a notice of deficiency, the timing of your response will shape the options available to you. Consultations are free, and we respond to new inquiries promptly. During the first conversation, we will review the notice, ask about the underlying return or tax year, and give you an honest assessment of where the case stands.
Contact us today to schedule a consultation, protect any deadlines that may apply to your situation, and take the first step toward resolving your IRS matter with experienced attorney-CPA representation.
