Tax Lawyer Amelia Island, FL
If the IRS or the Florida Department of Revenue has contacted you about a return, an assessment, or a balance due, it is essential to take action immediately. Administrative remedies depend on steps taken early, and conversations with agents at the examination stage often commit a taxpayer to positions that are difficult to revisit later.
Crepeau Mourges handles tax controversies for individuals, closely held businesses, executives, estates, and fiduciaries across Florida. Our founding partners hold credentials in both law and accounting, which means our Amelia Island, FL tax lawyer can read the return, reconstruct the records, and argue the legal position without handing the accounting work off to someone else. Schedule a free consultation today to discuss your matter.
Why Choose Crepeau Mourges as Your Tax Lawyer in Amelia Island, FL?
Dual Credentials in Tax Law and Accounting
Accounting training is not an optional enhancement in tax controversy work. It changes how quickly a representative can diagnose a case and how effectively they can communicate with revenue agents who speak in ledger terms.
Brian J. Crepeau studied accounting at Bridgewater State University, graduating in 1997, before earning his J.D. from American University, Washington College of Law in 2003. Brandon N. Mourges came to tax law from economics at The Wharton School at the University of Pennsylvania, followed by a J.D. and an LL.M. in Taxation from the University of Baltimore School of Law. Brandon holds memberships in the American Association of Attorney-CPAs, the Maryland Association of Certified Public Accountants, and the Federal Bar Association. Our tax lawyer in Amelia Island, FL brings that combined training to every engagement.
Four Decades of Tax Controversy Experience
The two founding partners have spent more than forty years collectively in federal and state tax disputes. Brian’s work centers on individual and corporate income IRS tax matters and on disputes involving brokers, financial planners, and investment advisers. Brandon focuses on individuals and businesses dealing with complex financial issues, including matters that cross into white-collar criminal territory. The firm’s clients include domestic taxpayers, foreign nationals with U.S. reporting obligations, estates, trusts, and closely held companies.
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 have used Brian for several complicated tax issues including the sale of a company and issuance of restricted stock. He is incredibly knowledgeable, thoughtful and professional. I have recommended Brian to several people because of my experience, and in speaking with them they have all experienced the same level of service that I did, which is the best compliment ever.” – John Ferrara
Read more reviews on our Google Business Profile.
Types of Tax Cases We Handle in Amelia Island
Our work for Amelia Island taxpayers spans federal and state matters in the following categories:
- IRS audits and examinations. We represent clients in field, office, and correspondence audits, including the information document request process, in-person interviews with revenue agents, and Form 4549 responses. An IRS audit can close with no change, a proposed assessment, or a referral to Appeals, and the outcome is shaped largely by how the record is developed in the first few weeks.
- IRS appeals and Tax Court. When an examination closes with an unagreed assessment, the taxpayer can file a written protest and take the case to the IRS Independent Office of Appeals. Most IRS tax appeals resolve on a hazards-of-litigation basis, with settlement authority Appeals holds that examination does not.
- State tax audits and appeals. Florida Department of Revenue examinations covering sales and use tax, corporate income tax, and reemployment tax follow their own informal protest procedures before reaching administrative hearing.
- Criminal tax investigations. IRS Criminal Investigation opens cases based on referrals from civil examination, bank reporting, and third-party information. A taxpayer who learns they are being investigated, or who is accused of tax fraud in a civil audit, needs help if accused of tax fraud from counsel before continuing any communication with the government.
- Offshore account compliance. U.S. persons with foreign financial accounts face reporting obligations under FBAR and FATCA, and penalties for non-willful and willful violations differ substantially. Correcting unreported offshore assets is done through the streamlined filing procedures or the IRS Voluntary Disclosure Program, and the choice between them depends on willfulness.
- Tax collection matters. Offers in compromise, installment agreements, currently-not-collectible status, and penalty abatement are the primary tools for resolving assessed balances with the IRS and state agencies.
- Tax liens and levies. A federal tax lien attaches automatically once assessment is made and notice of payment is ignored, and the IRS tax lien lawyer role is to pursue withdrawal, subordination, discharge, or release depending on the taxpayer’s situation and the property affected.
- Unfiled returns. Multiple years of missed filings can be brought current, but the structure matters. Catching up on unfiled tax returns without triggering criminal review requires careful sequencing and, in some cases, counsel-prepared returns rather than direct filings.
- Employment tax and trust fund recovery penalty. When a business falls behind on payroll tax deposits, the IRS can assess the full trust fund portion personally against owners, officers, and bookkeepers under IRC § 6672.
- Estate and gift tax. Audits of Form 706 and Form 709 frequently focus on valuation, and resolving estate and gift tax issues often depend on appraisal support and adequate-disclosure analysis.
Florida Legal Requirements for Tax Representation
A tax matter in Florida usually involves federal law first and state law second. Federal practice runs through the Internal Revenue Code and the Treasury Regulations, with procedure governed in part by IRS Circular 230. Circular 230 authorizes attorneys, CPAs, and enrolled agents to represent taxpayers before the Internal Revenue Service and sets the ethical standards that apply to that representation.
Florida residents benefit from the absence of a state personal income tax, set by the Florida Constitution at Article VII, § 5. Corporate taxpayers remain subject to the state corporate income tax under Chapter 220 of the Florida Statutes, and businesses collecting sales tax operate under Chapter 212. The Florida Department of Revenue administers both and opens audits on a regular cycle.
A few deadlines recur across almost every federal case. IRC § 6213 allows 90 days from a statutory notice of deficiency to file a petition in U.S. Tax Court, and that deadline cannot be extended. IRC § 6330 allows 30 days from a final notice of intent to levy to request a collection due process hearing. IRC § 6501 sets the ordinary assessment period at three years, stretches it to six years when income is substantially omitted, and removes it entirely in cases of fraud or failure to file.
Key Components of a Tax Case in Amelia Island
The Notice and the Deadline
The first useful question in any tax case is which notice the taxpayer has received. A 30-day letter, a 90-day letter, a Florida Department of Revenue assessment, and a final notice of intent to levy all look similar on the envelope and operate very differently. Each one starts a clock. Each clock governs a different set of rights.
Records and Return Analysis
The strength of a tax position usually comes down to what the underlying records show. Bank statements, depreciation schedules, basis calculations, and third-party information returns either support the filed position or they do not. Reviewing those documents carefully, and doing it with someone who reads financial records fluently, tends to narrow the dispute before the government ever weighs in.
Administrative Posture
Most tax disputes never see a courtroom. They resolve at examination, through the IRS Independent Office of Appeals, or during informal Florida protest procedures. Reaching a favorable administrative outcome depends on how the record is built from the first interaction forward. Concessions made early, sometimes without the taxpayer realizing it, are difficult to recover later.
Penalty Exposure
Federal civil penalties cover a wide range. IRC § 6662 imposes 20 percent accuracy-related additions. IRC § 6663 imposes 75 percent civil fraud penalties. Information return penalties, failure-to-file, and failure-to-pay additions stack on top. Relief from these penalties is available through reasonable cause arguments and first-time abatement procedures administered by the IRS, but the arguments need to fit the facts rather than simply recite the standard.
Criminal Exposure
Criminal risk in a tax case is identified from patterns, not from single entries. Unexplained bank deposits over time, cash handling without documentation, and consistent omissions that follow a theme can each draw attention from IRS Criminal Investigation. Recognizing those patterns early, and managing communications with the government accordingly, is often the most important judgment made in the case.
Collection Resolution
When the tax is owed and the question becomes how to pay it, the menu of options is narrower than many taxpayers assume. Offers in compromise require specific financial showings. Partial-pay installment agreements require ongoing compliance. Currently-not-collectible status lasts only as long as the hardship does. Bankruptcy discharge is possible for certain older income taxes but excluded for many others. Choosing among these options depends on the taxpayer’s full picture, not just the balance due.
Contact Crepeau Mourges
If you are facing a federal or state tax dispute in Amelia Island, how quickly and how carefully you respond will shape the options available for the rest of the matter. Consultations are free, and we respond to new inquiries promptly. During the first conversation, we will review the notice or documents you have on hand, discuss your options candidly, and give you an honest assessment of where the case stands.
Contact us today to schedule a consultation, protect any deadlines that may be running, and take the first step toward resolving your tax matter with experienced attorney-CPA representation.
