Los Angeles IRS Tax Controversy Attorney
Representation From a Former IRS Attorney and Collection Officer
Tax disputes with the IRS are stressful under any circumstances, and they become even more complicated when they arise in the context of a decedent's unpaid taxes, an estate tax audit, or a dispute over an estate's tax filings. Mitch Port spent years inside the IRS, both as an attorney in the Office of Chief Counsel and as a revenue and collection officer, before moving into private practice representing taxpayers.
That background gives our Los Angeles clients a genuine advantage: we know how the IRS actually builds its cases and what resolutions are realistically available, because we have seen the process from the other side of the table.
Tax Issues Arising From an Estate
When someone passes away, unresolved tax issues do not simply disappear. An estate can face IRS scrutiny over the decedent's unfiled or unpaid income taxes from prior years, an audit of the estate tax return itself, or disputes over asset valuations reported to the IRS. Executors and administrators can find themselves personally responsible for making sure these obligations are addressed before distributing estate assets, since failing to do so can create personal liability under federal law.
IRS Audits and Collection Actions
Beyond estate-related matters, we represent individuals and businesses facing IRS audits, proposed adjustments, and collection actions such as liens and levies. When a client owes back taxes they genuinely cannot pay in full, we evaluate options including an offer in compromise, which allows a taxpayer to settle a tax debt for less than the full amount owed under specific IRS guidelines, installment agreements, and penalty abatement requests for clients who have a reasonable cause for prior noncompliance.
Tax Court and Administrative Appeals
When a dispute cannot be resolved administratively, we represent clients before the United States Tax Court and through the IRS Office of Appeals. Understanding when to push for an administrative resolution versus when litigation is the better path is exactly the kind of judgment call that benefits from someone who has worked inside the system that is now on the other side of the negotiating table.
Frequently Asked Questions
Is an executor personally responsible for a decedent's unpaid taxes?
An executor can face personal liability if they distribute estate assets to beneficiaries while knowing about unpaid federal taxes, which is why addressing outstanding tax obligations before final distribution is such a critical step in probate and trust administration.
What is an offer in compromise and who qualifies?
An offer in compromise is an agreement with the IRS to settle a tax debt for less than the full amount owed, generally available to taxpayers who can demonstrate that paying the full amount would create financial hardship or that there is genuine doubt as to the amount owed or its collectibility. Not every taxpayer qualifies, and the application process requires detailed financial disclosure.
Call (310) 526-3433 to discuss your IRS matter with a former IRS attorney at the Law Office of Mitchell A. Port.
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"I highly recommend Mitchell A. Port"Living outside California, I needed an attorney from the Los Angeles area to handle my difficult LA Probate case. I went online and fortunately found a very experienced Probate Attorney in LA named Mitchell A. Port. Mitchell took my Probate case and did an excellent job helping me navigate through the intricacies of the LA Court Probate system. He quickly responded to any questions I had and was extremely knowledgeable about the steps required to complete the entire Los Angeles County Probate process. I highly recommend Mitchell A. Port to handle any of your future needs concerning the LA Court Probate system.- Randall
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"Knowledgeable, Personable and Results-oriented"Mitch is a great attorney - knowledgeable, personable and results-oriented. He helped me work through a challenging probate issue and his expertise was invaluable in terms of moving the case forward. Two thumbs up and five stars from me.- Jason
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"I found Mitch online and it was the best click I ever made"When I needed a probate attorney I found Mitch online and it was the best click I ever made. Thanks, Mitch- Norman S.
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"My brother and I have been so fortunate that my father chose Mitch Port to create his Trust!"My brother and I have been so fortunate that my father chose Mitch Port to create his Trust!- Cathy W
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"Mitch is compassionate, extremely knowledgeable and professional"
Mitch is compassionate, extremely knowledgeable and professional
- Lynne -
"Mitchell met my highest expectations."Mitchell met my highest expectations.- LaTrisha M
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"Mitch was awesome throughout this entire process and made this a stressless process."Mitch was awesome throughout this entire process and made this a stressless process.- M. C.
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"Probate cases can be difficult but attorney Mitchell Port makes them easier to understand."Probate cases can be difficult but attorney Mitchell Port makes them easier to understand.- Glendene W.
