NOTICE

After over forty years, John Y. Merrell, Jr is retiring from the practice of law effective October 7, 2018.  He thanks his many clients for the opportunity they have given him to practice law on their behalf. 

OLD PROFILE 

Merrell & Merrell, P.C. helps taxpayers resolve controversies with the Internal Revenue Service and state tax authorities. Its attorneys can help with (1) disputes over tax liability (i.e., how much you or your business owes); (2) disputes over tax collections (i.e., the amount and timing of tax payments); and (3) criminal tax investigations.

Disputes over Tax Liability. The Internal Revenue Code is incredibly complex. If you are being audited by the Internal Revenue Service, difficult issues often arise regarding the application of the Code to the precise facts of the case. Merrell & Merrell can analyze these issues and can assist in resolving them with the I.R.S. auditor. If an appropriate resolution cannot be reached with the I.R.S. auditor, Merrell & Merrell can take the matter before the Appeals Office of the I.R.S. Most issues are resolved there. However, should it become necessary, Merrell & Merrell can also take the matter to court. Merrell & Merrell has litigated scores of cases before the Tax Court, Court of Federal Claims, U.S. District Courts, Circuit Courts of Appeal and the United States Supreme Court.

Disputes over Collections. If you owe tax but cannot pay, there are many ways to structure payment over time. Moreover, depending on your circumstances, you may be able to make an offer in compromise, which will result in the payment of less than the full amount owed. Under 2012 changes in Internal Revenue Service procedures the Service is often willing to forgive large liabilities in exchange for payment of reasonable sum in a relatively short period of time.  Merrell & Merrell has helped many taxpayers, both businesses and individuals, resolve collection disputes on a favorable basis.  

Criminal Tax Investigations. If you are contacted by a Special Agent (criminal investigator) of the Internal Revenue Service or an Assistant United States Attorney concerning a tax matter, you or someone with whom you have dealt is probably under investigation for a criminal violation of the Internal Revenue Code. This is an extremely serious matter which will usually require the assistance of an attorney. If you are being questioned, it is advisable to politely refuse to answer any questions until you have had a chance to discuss the matter with an attorney.  Merrell & Merrell has successfully represented many individuals under criminal investigation. The firm has obtained jury acquittals of criminal tax charges and has frequently persuaded the Special Agent, Special Agent in Charge, Assistant United States Attorney or Tax Division of the Department of Justice to decline prosecution of taxpayers who have been investigated.

Reporting Foreign Financial Interests.  Merrell & Merrell can also help taxpayers with their obligation to report foreign assets, including bank and other financial accounts.  Voluntary disclosure can reduce criminal exposure and civil penalties for past failure to disclose foreign accounts or report the income from them.

Merrell & Merrell has dealt with the Internal Revenue Service, state taxing authorities and the Tax Division of the Department of Justice for over 50 years. The lawyers of Merrell & Merrell would be pleased to apply their years of experience to your case. To discuss your case or schedule an appointment, please contact our office.