What is a wrongful levy and how can I get it released?

   Tax levies are scary and are extremely debilitating for all taxpayers. Levies involve the actual seizure of property to satisfy a tax debt. Under Internal Revenue Code (“IRC”) 6331(a), the IRS has the right to seize and sell “all property and rights to property.” This means real or personal property and tangible or intangible property, including items such as a personal vehicle and residence, as well as wages, investment assets, receivables, and bank accounts. When the IRS first levies a taxpayer, the agency will follow a set process:The tax must first be assessed;The taxpayer will be sent a “Notice and Demand for...
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No Innocent Spouse Relief? No Problem.

If you fail to qualify for Innocent Spouse Relief under Treasury Regulation (“Treas. Reg.”) § 1.6015-2 and Separation of Liability Relief under Treas. Reg. § 1.6015-3, the good news is that you may still be entitled to tax, interest, and penalty assistance through Equitable Relief.What is Equitable Relief?General Conditions for Equitable Relief:According to Revenue Procedure 2000-15, the following threshold conditions must be satisfied before the IRS will consider a claim for Equitable Relief under IRC § 6015(f):The requesting spouse is not eligible for Innocent Spouse Relief, Separation of Liability Relief, or relief from liability arising from community property laws;The requesting spouse...
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Inside Biden’s Infrastructure Plan: Tax Consequences to be Aware of

I Making headlines over the past few months has been the Biden administration’s Infrastructure Plan. On September 15, 2021, the House Ways and Means Committee advanced part of the Build Back Better Act, which includes proposed tax changes expected to generate over $2 trillion in federal funds. In total, the House bill is expected to cost $3.5 trillion. In August, the Senate also passed its version of the infrastructure bill, which is limited to $1 trillion in federal spending. According to House Speaker Nancy Pelosi, Biden’s $4.5 trillion infrastructure plan is expected to pass by the end of September. Changes made to...
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Surprise! Spouse Leaves IRS Debt You Did Not Know About

 When filing a joint tax return, married taxpayers are often privy to certain tax benefits. Generally, married taxpayers take advantage of a higher standard deduction and a lower tax rate when filing their taxes together. However, as a result of a joint filing, both taxpayers are equally responsible for the possible liability that comes with joint filing status. But what if one spouse wasn’t exactly honest about their income when filing the tax return, and the other spouse didn’t know? By requesting Innocent Spouse Relief, a spouse can be relieved of the responsibility for paying tax, interest, and penalties if the...
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Lee Wilson Certified by the Texas Board of Legal Specialization: Tax Law

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The Wilson Firm is excited to announce that Managing Attorney Lee Wilson is officially certified by the Texas Board of Legal Specialization in Tax Law! 

There are only 191 Board Certified Tax Law Lawyers in the entire state of Texas. 

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Lee Wilson selected to Super Lawyers' Rising Stars for third consecutive year.

 The Woodlands, Texas - Lee Wilson, Managing Attorney of The Wilson Firm, PLLC, was selected to Super Lawyers' Rising Stars again this year, making it three consecutive years that he has been honored accordingly. The Rising Stars designation is reserved for the top two-percent (2%) of attorneys in Texas. The Wilson Firm is a boutique tax law f...
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Lee Wilson selected to Rising Stars list for the 6th year!

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New Associate Attorney, Dane Rebkowec, joins The Wilson Firm.

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The Wilson Firm is excited to announce that Dane Rebkowec has joined the firm as of March 9, 2020.

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Introducing the U.S. Tax Court Podcast

The Woodlands, Texas Below is a link to a new podcast created by myself and Rik Thakrar, a fellow tax lawyer in Orlando, Florida. The weekly podcast focuses on practice in the U.S. Tax Court from our perspective as practicing attorneys. The really great part about the podcast is we focus on the history leading up to certain cases, the law to come o...
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