Tax Lawyer In Southfield, MI

A Southfield tax lawyer from Austin & Larson Tax Resolution combines three credentials no solo CPA or national chain matches at the same firm: a Juris Doctor for legal representation, an Enrolled Agent license for full IRS practice rights, and a CPA license for accounting depth. The pairing matters when a partnership audit, an S-corp reasonable compensation challenge, or a large-dollar IRS examination requires legal strategy and accounting execution on the same team.

The three structural options a Southfield professional weighs:

Solo CPA. Prepares your return well. Handles examination-level audits where the issues are straightforward. Cannot represent you in IRS collection actions, cannot represent you in appeals once formal, and cannot litigate in U.S. Tax Court. When the case escalates, the CPA refers out, usually to a firm that does not know your facts.

National tax chain. Sells your case through a call center. Transfers to a case manager. Transfers again to a resolution specialist. Each handoff loses information. Generic process, limited Michigan Department of Treasury knowledge, and rarely any single attorney accountable for outcome.

Austin & Larson Tax Resolution. One team from consultation through resolution. JD plus EA plus CPA credentials in-house. Michigan-based knowledge of both IRS and Michigan Treasury procedures. No handoff loss. Bridgette Austin’s JD covers Tax Court litigation. Dustin Larson’s CPA covers complex accounting reconstruction. Both Enrolled Agent licenses cover IRS practice procedurally.

You need a tax lawyer in Southfield, MI when the matter has moved past return preparation into legal territory: collection, appeals, criminal exposure, Tax Court, or any entity-level partnership or S-corporation audit. A CPA can prepare and defend an examination-level audit. The work that follows requires a different license. Austin & Larson Tax Resolution covers both sides because Bridgette Austin’s JD plus EA combination and Dustin Larson’s CPA plus EA combination span the entire tax controversy practice.

For Southfield professionals and business owners, the triggers that move a case from CPA work to attorney work:

• IRS Letter 1058 (Final Notice of Intent to Levy) or CP504.
• Active wage garnishment, bank levy, or business account levy.
• A partnership audit notice under the Bipartisan Budget Act (BBA) Centralized Partnership Audit Regime.
• An IRS K-1 inconsistency notice (you and the partnership reported different amounts).
• An S-corporation reasonable compensation inquiry.
• A Section 199A Qualified Business Income deduction adjustment.
• Three or more years of unfiled returns at the entity or personal level.
• A Statutory Notice of Deficiency with a 90-day Tax Court petition window.
• Large-dollar exposure (typically $50,000 and above) with a Revenue Officer assigned.
• IRS Criminal Investigation contact.
• A Michigan Department of Treasury audit notice.
• A Section 1031 like-kind exchange that failed identification or closing deadlines.
• Depreciation recapture exposure on real estate dispositions.

Most Southfield cases that reach our office involve more than one of these triggers. The combination is what makes representation valuable.

The IRS offers several formal programs for resolving tax debt. The right program depends on financial situation, total balance, and case posture. Austin & Larson Tax Resolution pulls your IRS account transcripts, runs the financial analysis (Form 433-A or Form 433-B), and recommends a path before any program is filed. Common options for Southfield clients are Installment Agreement, Offer in Compromise, Currently Not Collectible status, Penalty Abatement, Innocent Spouse Relief, and CSED expiration strategy.

Installment Agreement (IA). Monthly payment plan. Streamlined IAs under $50,000 approve in 30 to 60 days with limited documentation. Higher-balance IAs require Form 433 financial disclosure and typically resolve in 60 to 120 days. Many Southfield professional and business clients qualify for full-pay or partial-pay IAs because of strong income relative to allowable expense standards, which makes the IA the most common resolution path for this demographic.

Offer in Compromise (OIC). Settles the debt for less than the full amount owed when the IRS agrees you cannot pay in full. Filed on Form 656 with Form 433-A (OIC) financial disclosure. The IRS calculates Reasonable Collection Potential from disposable income and asset equity. Most accepted OICs settle between 10 and 40 cents on the dollar. Timeline: 6 to 12 months. Acceptance rate is roughly 30 percent, which is why financial analysis matters before filing.

Currently Not Collectible (CNC). Pauses IRS collection when you cannot pay anything without falling below allowable living expense standards. Less common for Southfield clients given the income demographic, but applicable in cases with significant short-term income disruption, divorce, or medical hardship.

Penalty Abatement. Removes failure-to-file, failure-to-pay, and accuracy-related penalties. First-Time Abatement applies if you have a clean compliance history. Reasonable Cause abatement applies for documented illness, disaster, hardship, or reliance on professional advice. Penalty abatement on a large-dollar case can recover $25,000 or more in a single filing.

Innocent Spouse Relief. Removes joint liability for tax problems attributable to your spouse or ex-spouse. Filed on Form 8857, generally within two years of the IRS beginning collection against you.

CSED expiration strategy. The IRS has 10 years from the date of assessment to collect a tax debt. Once the Collection Statute Expiration Date passes, the debt is legally uncollectible. Certain actions pause the clock. We calculate exact CSED dates on every case as part of the initial transcript review.

What happens during an IRS BBA partnership audit?

The Bipartisan Budget Act Centralized Partnership Audit Regime, in effect since 2018, audits partnerships at the entity level by default. The IRS sends an audit notice to the partnership representative (a designated individual or entity with binding authority). The partnership representative makes decisions on behalf of all partners, including settlement, push-out elections, and litigation positions. The default outcome is an entity-level assessment at the highest individual tax rate. Partners can push out the adjustment to their personal returns through a formal Section 6226 election, but the election has procedural and timing requirements. Austin & Larson Tax Resolution represents partnerships through BBA audits and advises partnership representatives on push-out decisions.

How does the IRS determine reasonable compensation for an S-corporation shareholder?

The IRS reviews reasonable compensation when an S-corporation shareholder takes high distributions and low or no salary. Distributions are not subject to payroll tax; salary is. The IRS applies a multi-factor analysis: industry compensation data, the shareholder’s duties and time commitment, training and experience, comparable salary surveys, and the financial condition of the business. Reasonable compensation is often the largest line item in an S-corp audit adjustment, with payroll tax assessment plus penalties on the underpaid wages. Austin & Larson Tax Resolution benchmarks reasonable compensation, defends existing salary practices, and restructures where audit risk is significant.

Do you serve Southfield, MI without a local office?

Yes. Austin & Larson Tax Resolution has three Michigan offices: Brighton, Lansing, and Saginaw. We do not have a Southfield office. Our Brighton office is roughly 30 miles from Southfield and serves as the in-person meeting location for Town Center, I-696, and Telegraph Road corridor clients. Most case work happens through phone consultations, secure video meetings, and an encrypted document portal. The IRS works with your representative by mail, fax, and phone, not by physical visit, so a Southfield case runs identically to one for a client closer to the Brighton office.

When do I need a tax lawyer in Southfield, MI instead of a CPA?

You need a tax lawyer in Southfield, MI when the matter has crossed into legal territory: collection, appeals, criminal exposure, Tax Court, or entity-level partnership or S-corporation audits. CPAs handle return preparation and examination-level audits well. They are not licensed for the work that follows. For Southfield professionals and business owners, the most common triggers are partnership audit notices under BBA, K-1 inconsistency notices, S-corp reasonable compensation inquiries, Section 1031 like-kind exchange complications, and large-dollar (above $50,000) IRS examinations with a Revenue Officer assigned. Austin & Larson Tax Resolution covers both the legal and accounting sides under one roof.

How does Section 1031 like-kind exchange work for real estate investors?

Section 1031 defers capital gains tax when you sell real estate and replace it with like-kind property within strict deadlines. You must identify replacement property within 45 days of the sale and close on the replacement within 180 days. The exchange must run through a qualified intermediary; you cannot touch the sale proceeds. Failure on any procedural point produces a failed exchange and a fully taxable sale, often with significant capital gains and depreciation recapture exposure. Austin & Larson Tax Resolution represents Southfield real estate investors through 1031 procedural complications and defends the deferral on audit when the IRS challenges identification or closing timing.

How long does it take to resolve IRS tax debt?

Timelines depend on the program. An Installment Agreement under $50,000 sets up in 30 to 60 days. A higher-balance IA with full financial disclosure runs 60 to 120 days. Penalty Abatement resolves in 60 to 120 days. An Offer in Compromise takes 6 to 12 months. A BBA partnership audit can run 12 to 24 months depending on entity complexity and whether push-out elections are involved. A large-dollar individual audit runs 9 to 18 months on average. Active collection (wage garnishment, bank levy) pauses within 24 to 72 hours of Austin & Larson filing Form 2848 on your behalf.

Does the IRS forgive old tax debt?

The IRS has 10 years from the date of assessment to collect a tax debt. This is the Collection Statute Expiration Date (CSED). Once the CSED passes, the IRS legally cannot collect the debt. The clock starts when the tax is assessed, not when the income was earned. Certain actions pause the clock: bankruptcy filings, pending Offer in Compromise reviews, and Collection Due Process appeals. For Southfield clients with older partnership or business tax debts, exact CSED calculation can substantially change the resolution strategy. We calculate CSED on every case during the initial transcript review.

Is the consultation actually free?

Yes. The initial consultation is free with no obligation to engage. It happens by phone, by secure video, or in person at our Brighton office. We review your IRS or Michigan Treasury notices, walk through the facts (including K-1 issues, partnership audit notices, large-dollar exam letters, real estate investor matters, or whatever the situation requires), and tell you straight what the realistic resolution path looks like. We do not pressure-sell, and we will not take a case where engagement does not make financial sense for the client.