Assuming certain conditions are met, this limitation will apply if within that 18-month period the IRS does not provide the taxpayer with a notice stating the taxpayer's liability and the basis of the liability. This new provision may help to eliminate the delays that now frequently occur in audits. If the IRS, nevertheless, drags out an audit for years, at least the taxpayer's interest bill will not be increasing the entire time. Reports of enormous sums awarded to seemingly unworthy plaintiffs have lead wealthy individuals to look for methods to insulate themselves from risk. Part of our job as estate planners is to assure that most of a client's assets are passed to the next generation.
Asset protection is part of that process.
Click for further information and resources on asset protection. It is a tax law firm with three lawyers and three paralegals. The majority of our clients are in Santa Barbara County, California, but we also represents clients in other areas of Northern and Southern California. We work closely with our clients' professional advisors. In our litigation practice, we represent taxpayers at the audit, at IRS Appeals, in Tax Court, and before the Ninth Circuit Court of Appeals.