Brotman Law — IRS tax debt resolution attorneys San Diego

Tax Defense

IRS Tax Debt Resolution
Settle for Less. Move Forward.

You don't have to live under the weight of IRS tax debt. We negotiate settlements, payment plans, and penalty reductions that let you get back to your life.

Sam BrotmanSam Brotman, J.D., LL.M.|Last updated April 2026

Key Takeaway

The IRS has formal programs to resolve tax debt — installment agreements, offers in compromise, currently-not-collectible status, and penalty abatement. The key is knowing which program fits your specific financial circumstances.

The IRS Says You Owe. That Doesn't Mean You Have to Pay Every Penny.

IRS tax debt is overwhelming. The letters keep coming, the penalties and interest keep growing, and the threat of liens, levies, and wage garnishment creates constant stress. It feels like there's no way out.

But there is. The IRS has formal programs designed to help taxpayers resolve their debt — offers in compromise, installment agreements, currently-not-collectible status, and penalty abatement. The problem is that most people don't know these options exist, or they try to navigate the process without professional help.

We've resolved millions of dollars in IRS tax debt for our clients. We know which resolution strategy works best for each situation, how to present your case to maximize your chances of approval, and how to protect you from collection actions while we negotiate.

The IRS is a bureaucracy. It responds to process, documentation, and persistence. That's exactly what we provide.

From Our Practice

We've negotiated hundreds of IRS settlements — from installment agreements to offers in compromise that resolved six- and seven-figure tax debts for pennies on the dollar. The IRS has formal programs for every situation, and knowing which program fits your circumstances is the key to resolution.

Resolution Options

IRS Tax Debt Resolution Services

Offer in Compromise

Settle your tax debt for less than the full amount owed. We prepare compelling OIC applications that demonstrate your inability to pay the full balance, using the IRS's own formulas to maximize your savings.

Installment Agreements

Structured monthly payment plans that stop collection activity and let you pay your debt over time. We negotiate terms that fit your budget while satisfying the IRS's requirements.

Currently Not Collectible

If you genuinely can't pay, we get the IRS to place your account in CNC status — stopping all collection activity while the statute of limitations continues to run.

Penalty Abatement

IRS penalties can double your original tax bill. We pursue first-time abatement, reasonable cause arguments, and statutory exceptions to eliminate or reduce penalties.

Lien & Levy Release

The IRS has seized your bank account or filed a lien on your property. We take immediate action to release levies, subordinate liens, and protect your assets.

Innocent Spouse Relief

Unfair tax debt from a spouse or ex-spouse? We file for innocent spouse relief, separation of liability, or equitable relief to remove your share of jointly-owed tax.

Understanding Your Options

IRS Tax Debt: What You Need to Know

What is an Offer in Compromise?

An Offer in Compromise (OIC) lets you settle your tax debt for less than you owe. The IRS evaluates your income, expenses, assets, and future earning potential to determine the minimum amount they'll accept. In the right circumstances, you can settle a six-figure debt for pennies on the dollar.

The key is presenting your financial situation accurately and persuasively within the IRS's specific methodology. We know exactly how the IRS evaluates OICs and how to structure applications for maximum approval.

When should I consider an installment agreement?

Installment agreements are appropriate when you can pay your full tax debt but need time. The IRS offers several types: streamlined (for debts under $50,000), non-streamlined (requiring financial disclosure), and partial-pay installment agreements (where the payment amount won't fully cover the debt before the statute expires).

We negotiate terms that balance what you can afford with what the IRS will accept, and we ensure the agreement protects you from further collection action.

What is Currently Not Collectible status?

CNC status means the IRS has determined you can't afford to pay anything right now. They stop all collection activity — no levies, no garnishments — while your account remains in this status. The critical benefit is that the 10-year collection statute of limitations keeps running.

If your financial situation doesn't improve before the statute expires, the debt is written off. CNC is a powerful tool when used strategically.

How do IRS penalties and interest work?

The IRS charges a failure-to-file penalty (5% per month up to 25%), a failure-to-pay penalty (0.5% per month up to 25%), and interest on the unpaid balance. These compound over time and can easily double your original tax bill.

We pursue every available penalty abatement strategy: first-time abatement for taxpayers with clean compliance history, reasonable cause for taxpayers who had legitimate reasons for non-compliance, and statutory exceptions for specific circumstances.

What is the 10-year collection statute?

The IRS generally has 10 years from the date of assessment to collect a tax debt. After that, the debt expires and is written off. This is called the Collection Statute Expiration Date (CSED).

Understanding your CSED is critical to choosing the right resolution strategy. In some cases, the best approach is to run out the clock rather than settle or pay.

Talk to a Tax Attorney

Not Sure Where You Stand?

Schedule a free 15-minute call. We'll assess your situation, outline your options, and tell you exactly what to expect — no obligation.

Book Your Free Call

or call (619) 378-3138

Why Brotman Law

Tax Debt Resolution That Actually Works

Millions Resolved

We've negotiated millions of dollars in IRS tax debt settlements. We know what works and what doesn't.

Every Option Explored

We don't push one-size-fits-all solutions. We analyze your situation and recommend the strategy that produces the best outcome.

Collection Protection

While we negotiate, we take immediate action to stop levies, release liens, and protect your assets from IRS seizure.

Real Tax Attorneys

Not TV spokespeople or call centers. Licensed tax attorneys who handle your case personally and fight for every dollar.

Transparent Pricing

No hidden fees or surprise charges. We explain our fees upfront so you know exactly what your resolution will cost.

Long-Term Strategy

We don't just resolve today's debt. We help you build a tax-compliant future that prevents new problems from arising.

Free Guide

Read our IRS Collections Guide

A comprehensive, attorney-written resource covering everything you need to know about this topic.

Related services: IRS Audits  •  Criminal Tax Defense  •  California FTB Defense

Also consider: Business Tax Optimization  •  Individual Tax Optimization

Frequently Asked Questions

IRS Tax Debt FAQs

How much can I settle my IRS tax debt for?

It depends on your income, expenses, assets, and future earning potential. Some clients settle for pennies on the dollar, while others find installment agreements or CNC status more appropriate. We evaluate your specific situation during a free intro call.

Will the IRS accept my Offer in Compromise?

The IRS accepts approximately 30-40% of OIC applications. Our acceptance rate is significantly higher because we pre-qualify clients and prepare applications that meet the IRS's specific criteria. We don't file OICs that we don't believe will be accepted.

Can the IRS take my house?

The IRS can file a tax lien on your home and, in extreme cases, seize real property. However, property seizures are relatively rare and require internal IRS approval. We take immediate action to prevent seizure and negotiate alternatives.

What is the IRS Fresh Start Program?

Fresh Start is an IRS initiative that expanded access to installment agreements and offers in compromise. It increased the threshold for streamlined installment agreements to $50,000 and made OIC qualification criteria more flexible.

How long does IRS tax debt resolution take?

Timelines vary by strategy. Installment agreements can be set up in weeks. Offers in compromise typically take 6-12 months for IRS review. Currently not collectible determinations can be established relatively quickly. We protect you from collection activity throughout the process.

Can I negotiate with the IRS myself?

You can, but the IRS is not on your side. They have no obligation to tell you about all available options, and their revenue officers are trained to maximize collections. Having an attorney negotiate on your behalf typically produces significantly better outcomes.

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Get Started Today

Book Your Free 15-Minute Call

Schedule a brief call with our team to discuss your situation. We'll assess where things stand and outline your options — confidentially and without obligation.

  • Completely confidential — protected by attorney-client privilege
  • Every situation is different — you'll receive a custom assessment tailored to yours
  • Same-day and next-day appointments available