When You Have Serious Tax Issues, You Need Someone Who Knows Tax Law

Atlanta Back Tax Relief Attorney And IRS Debt Settlement

The IRS pursues people who owe back taxes, even what one might consider “small” amounts. Amounts as small as $10,000 can mean significant interest and penalties. So it is wise to take action when you owe back taxes. You may also have resources that you are not aware of that offer protection.

Our Services

Since 1982, Atlanta tax attorney and CPA Jeffrey S. Gartzman has helped thousands of taxpayers with IRS tax relief from back taxes and IRS tax debt. His work is comprehensive. He represents individuals and businesses in a host of issues, including:

Unfiled tax returns and back taxes
Amending tax returns
Resolving penalties for tax issues
Issues involving tax levies, garnishments and property seizures
Audits and appeals
Foreign bank account/asset cases
Payroll tax issues and Trust Fund Penalty cases

His case history includes representing individuals with hundreds of thousands of dollars in tax debt and other serious issues. He has represented individuals who face criminal consequences.

Tax Resolution For Back Tax Collection

Our firm is at the ready. Armed with a detail-oriented tax attorney and over 40 years of experience, The Gartzman Law Firm, P.C., can assist with complex state and federal tax issues. We are up to date on the latest developments and stay abreast of your legal obligations.

After a detailed personalized analysis, Atlanta tax attorney Jeffrey S. Gartzman will develop a plan that accounts for all the possible factors, including:

Exploring your rights to a payment plan or installment agreement
Reviewing options for Offers in Compromise
Reviewing the statute of limitations on back taxes
Appealing your case with the IRS or in Tax Court
Determining your eligibility for Innocent Spouse Tax Relief

No two tax situations are the same. Whatever the size of your liability or the stage of IRS collection, our firm works to find a path forward that protects you and makes the most of every option available under the law.

How Much Will The IRS Settle For? Understanding Reasonable Collection Potential (RCP)

When a taxpayer cannot pay the full balance owed, the IRS may accept a lump-sum settlement through its Offer in Compromise (OIC) program. The IRS bases its decision on one figure: how much it calculates it can realistically collect from you before your tax debt expires. That figure is called Reasonable Collection Potential, or RCP.

RCP is the IRS’s calculation of how much it can realistically collect from you before your tax debt expires. The formula works in two parts. First, the IRS calculates the net realizable equity in all of your assets, bank accounts, real estate, vehicles and investments, each discounted to a quick-sale value and reduced by any secured liabilities. Second, it multiplies your monthly disposable income (total income minus IRS-allowable living expenses) by either 12 or 24 months depending on the payment structure you propose. Those two figures added together equal your RCP.

Your offer must equal or exceed that number. If your RCP comes out to $8,000 on a $95,000 liability, the IRS can legally accept $8,000 and release the rest. If your RCP is $60,000 on the same debt, a much smaller reduction is realistic. This is why a precise financial evaluation conducted by someone trained in both tax law and accounting determines whether an OIC makes strategic sense before you file one.

Filing an OIC requires a $205 nonrefundable application fee and a 20% nonrefundable deposit on your proposed amount at submission. All tax returns must be current, and you must stay in full compliance for five years after acceptance. A failure on either condition reinstates the full original liability.

Resolving Large Back Tax Debts: $100,000-Plus Liabilities

For taxpayers with significant IRS balances who do not qualify for an Offer in Compromise, two other resolution tracks are available.

Partial Pay Installment Agreement (PPIA)

A Partial Pay Installment Agreement (PPIA) lets you pay only what you can actually afford each month. Unlike a standard installment agreement, a PPIA does not require full repayment over time. You make payments based on your current financial capacity and whatever balance remains when the IRS’s Collection Statute Expiration Date (CSED) runs, generally 10 years from the date of assessment, is legally extinguished.

The IRS reviews your finances every two years and can adjust the payment upward if your income improves. A PPIA requires full financial disclosure on Form 433-A or 433-F and acceptance of the IRS Collection Financial Standards for household expenses. This option works best when the CSED is within five years and your disposable income is limited.

Currently Not Collectible (CNC) Status

If your income does not exceed the IRS’s allowable living expenses after applying its Collection Financial Standards, your account may qualify for Currently Not Collectible (CNC) status. Once the IRS places your account in CNC, collection activity stops. Levies, wage garnishments and collection notices pause while the CSED keeps running in the background. The debt is not forgiven, but many CNC accounts ultimately expire without a single payment ever being made.

CNC status requires documented proof that nothing remains available for IRS payments after allowable expenses. The IRS reviews CNC accounts periodically, and if your financial picture improves, collection can resume. Our firm monitors those review cycles and represents clients when the IRS moves to reclassify their account.

Georgia DOR Back Tax Settlements And State Relief

Federal tax debt and Georgia state tax debt are handled by separate agencies under separate rules. A settlement you reach with the IRS has no effect on what the Georgia Department of Revenue (DOR) can still collect.

Georgia’s DOR operates its own Offer in Compromise program. The minimum settlement amount is based on the same general framework as the federal program: net equity in your assets plus the amount the Department projects it can collect from your future income. Georgia accepts offers on three grounds: Doubt as to Collectibility (you cannot pay even through a payment plan or by liquidating assets), Doubt as to Liability (you have legitimate grounds to dispute what you owe) and Economic Hardship (you could technically pay but collection would cause serious financial harm).

Georgia also offers installment payment agreements for taxpayers who need time to pay. To submit a Georgia OIC, you file Form OIC-1, complete Form CD-14C for individuals, provide three months of bank statements and recent pay stubs and submit a $100 nonrefundable application fee unless you qualify for the low-income exemption. All required state returns must be filed and no active bankruptcy can be pending.

Our firm handles both the IRS and Georgia DOR sides of a resolution simultaneously so no window closes while you are focused on one agency.

Why Partner With An Atlanta Tax Attorney And CPA For Settlement

The Offer in Compromise and PPIA processes are not built for self-representation. A miscalculated RCP, an overstated expense category, an unreported asset or a missed filing can result in rejection, forfeiture of your nonrefundable deposit or aggressive collection action during the review period itself.

Atlanta tax lawyer Gartzman brings more than 40 years of combined tax law and CPA experience to every case, along with an LL.M. in Taxation. That dual qualification matters in IRS negotiations. An attorney protects your rights and advocates before the agency. A CPA builds the financial case that supports your offer. Gartzman does both, so the legal strategy and the financial analysis come from the same evaluation.

Our firm determines whether an OIC, PPIA, CNC status or another resolution is the right fit before anything is filed. For individuals and business owners in Fulton County, DeKalb County and across Metro Atlanta who owe $20,000 to $100,000 or more in federal or Georgia state back taxes, that up-front assessment can define the outcome.

Frequently Asked Questions About IRS And Georgia Back Tax Settlement

Atlanta taxpayers dealing with significant back tax liabilities often have the same core questions before they call. Here are straightforward answers to three of the most common ones.

How much will the IRS usually settle for in an Offer in Compromise?

The IRS does not settle for a fixed percentage. It settles for your Reasonable Collection Potential, calculated from your specific assets and monthly disposable income after allowable expenses. If your net equity is low and your income barely covers the IRS living standards, an offer of five to 15 cents on the dollar may be realistic. If you own significant property or carry steady income, your RCP will be higher and so will the minimum offer. The only reliable way to know your number is to run the calculation with accurate, documented figures.

What options do I have if I owe over $100,000 in back taxes?

Owing six figures to the IRS does not mean you owe it all at once. Depending on your financial situation, you may qualify for an Offer in Compromise to settle for less than the full balance, a Partial Pay Installment Agreement that caps your monthly payment and lets the remaining balance expire at the CSED or Currently Not Collectible status that pauses all collection while the statute runs. Each option requires full financial disclosure and carries its own conditions. Our firm evaluates all three and recommends the path that limits your total exposure.

Can the Georgia Department of Revenue settle state back tax debts?

Yes. Georgia runs its own Offer in Compromise program separate from the IRS process. The minimum settlement amount is based on your net asset equity and projected collectible income. Georgia accepts offers on three grounds: Doubt as to Collectibility, Doubt as to Liability and Economic Hardship. All required Georgia returns must be current and no bankruptcy can be active when you apply. Once an offer is accepted and payment is received in full, the state tax execution is released.

Contact An IRS Or State Back Tax Help Attorney

Get the experience of over 40 years on your side to fix your IRS or state tax problems, find tax relief and settle tax debt. Call 770-695-7337 to speak with a tax attorney at The Gartzman Law Firm, P.C., today, your IRS Tax Relief Team. You may request a consultation via email if more convenient. Our Atlanta, Georgia, back tax help attorney aims for success in representation in settling your back tax matters professionally, ethically and successfully.