When the IRS or the New York State Tax Department comes after you, they have one goal: collect as much as possible, as fast as possible. They have experienced agents, automated systems, and the full force of federal and state law behind them.
You don’t have to face that alone.
For over 20 years, tax attorney Charles Rosselli has represented individuals and businesses with serious IRS and New York State tax problems — from a first collection notice all the way through Tax Court if necessary.
Tax lawyer Charles Rosselli knows how the IRS & NYS Tax Department operate, how they negotiate, and how to use that knowledge to protect you.
The cases he handles range from $20,000 to $2.5 million. Whether you’re an individual dealing with years of back taxes or a business owner facing a sales tax audit and a personal responsible-person assessment, he has seen it and resolved it.
IRS Tax Problems We Routinely Resolve
The IRS has broad collection powers — and they use them. A tax lien can cloud your property. A levy can empty your bank account overnight.
A wage garnishment can take a significant portion of every paycheck until the balance is paid. None of these outcomes is inevitable when you have the right attorney involved early.
Here is what tax attorney Charles Rosselli routinely handles for clients dealing with the IRS:
Settling IRS Tax Liabilities
If you owe the IRS money you can’t pay in full, there are several legitimate paths to resolution — installment agreements, partial pay agreements, collection statute strategies, penalty abatement, currently not collectible status, and offers in compromise. The right option depends on your specific financial situation, compliance history, and fact pattern. Tax attorney Charles Rosselli will analyze your IRS matter and position it for the best outcome with the IRS.
Offer in Compromise
Under the right circumstances, an Offer in Compromise allows qualifying taxpayers to settle their IRS debt for less than the full amount owed. The IRS has strict eligibility criteria and rejects poorly prepared offers. Tax attorney Charles Rosselli routinely prepares and negotiates offers with a thorough understanding of the nuances and details of the IRS tax laws — giving your offer the best possible chance of acceptance.
Properly Structured Partial Pay Agreements
In certain circumstances, we can save a client money through a properly structured agreement with the IRS while simultaneously stopping civil enforcement.
Penalty Abatement
The IRS charges significant penalties on top of the underlying tax — failure to file, failure to pay, and accuracy penalties can dramatically increase what you owe. In certain cases, those penalties can be reduced or eliminated entirely.
Bank Levies and Wage Garnishment
If the IRS has already levied your bank account or garnished your wages, time is critical.
IRS Revenue Officer Representation
An IRS Revenue Officer assigned to your case means the IRS is taking your situation seriously. Revenue Officers have broad authority and can move quickly to collect. Having tax attorney Charles Rosselli step in immediately changes the dynamic — all communication goes through our tax law firm, and you stop dealing with the IRS directly.
Help with IRS Notices
Some taxpayers do not know where their tax matter stands with the IRS. We are able to review the tax files and advise the taxpayer as to the next best step to resolve the tax matter most favorably.
Unfiled Income Tax Returns
Years of unfiled returns create compounding problems — substitute returns filed by the IRS on your behalf, growing penalties, and potential criminal exposure. Getting into compliance requires a strategic approach: filing returns in the right order, with the right documentation, while simultaneously negotiating the resolution of any resulting balance.
Business and Payroll Tax Problems
Unpaid payroll taxes — trust fund taxes — are among the most serious IRS issues a business can face. The IRS can hold business owners and responsible parties personally liable for the employee portion of unpaid payroll taxes, even if the business has closed. Tax lawyer Charles Rosselli represents both the business and the individuals at risk.
IRS Audit Representation
An IRS audit doesn’t have to be a disaster. Proper representation means the IRS gets what it’s legally entitled to — and nothing more.
Appeal Representation
We have seen tremendous success in obtaining the proper result for our clients at Appeals. Proper strategy and timing are critical.
US Tax Court Representation
Certain tax matters require judicial intervention. Tax attorney Charles Rossell is licensed to represent you in the United States Tax Court.
New York State Tax Problems We Routinely Resolve
New York State is one of the most aggressive tax collection jurisdictions in the country. The New York State Tax Department moves fast — issuing warrants, suspending driver’s licenses, and sending Tax Agents to homes and businesses with less warning than the IRS typically provides. If you have an unresolved NYS tax problem, the time to act is now.
Here is what tax attorney Charles Rosselli routinely handles for clients dealing with the New York State Department of Taxation and Finance:
NYS Income Tax Liabilities
Whether you owe from a prior year assessment, an audit adjustment, or years of unfiled state returns, New York tax attorney Charles Rosselli will negotiate with the New York State Tax Department to resolve your income tax balance under the most favorable terms available.
NYS Tax Warrant
A New York State tax warrant is the equivalent of a judgment lien — it attaches to your property and appears in public records. Warrants must be addressed before they escalate to active collection. I work to vacate, satisfy, or resolve warrants as part of a broader resolution strategy.
New York State Sales Tax Audits
NYS sales tax audits are among the most technical and high-stakes matters a business owner can face. The New York State Sales Tax Department uses statistical sampling and markup methods that can dramatically inflate an assessed liability. NY tax attorney Charles Rosselli represents businesses through the full audit process — from the initial information request through the audit, the conciliation conference, and appeal if necessary.
New York State Sales Tax Liabilities
New York State sales tax liabilities will eventually result in the seizure and closure of your business if not properly addressed. You will be held personally responsiblle for the sales tax liabilities of your business personally.
Responsible Person Assessments [ NYS Sales Tax ]
If your business has unpaid sales tax, New York State can assess the tax personally against owners, officers, and anyone deemed responsible for collecting and remitting sales tax. This means your personal assets — your home, your savings, your future income — are at risk. I defend responsible person assessments and negotiate the personal liability down wherever possible.
NYS Voluntary Disclosure
If you have unreported income or unfiled New York State returns, the NYS Voluntary Disclosure program can allow you to come forward, pay what you owe, and avoid criminal prosecution and significant penalties. Timing, the languaging of the agreement, and proper structuring of the disclosure are everything — this is not something to navigate without an experienced NY tax attorney.
Unfiled New York State Tax Returns
Individual income tax, business income tax, sales tax — years of unfiled NY returns create serious exposure. I bring clients into compliance strategically, managing the filing process alongside the resolution of any resulting balance.
NY Driver’s License Revocation
New York State can suspend your driver’s license for unpaid tax debt over a threshold amount. This can happen with very little notice and has immediate practical consequences for your livelihood. License suspensions tied to tax debt can be addressed as part of the broader resolution process.
NYS Tax Agent Representation
A New York State Tax Agent visiting your home or business is a serious escalation. Like an IRS Revenue Officer, a Tax Agent has broad authority and is there to collect. I step in immediately, redirect all contact through my office, and get a resolution strategy in place.
NY Installment Agreements and Payment Plans
When full payment isn’t possible, New York State offers payment plans — but the terms and sustainability of those plans matter. I negotiate installment agreements that you can actually maintain without defaulting and triggering renewed collection action.
Penalty Abatement
New York State imposes substantial penalties for failure to file and failure to pay. In appropriate cases, those penalties can be challenged and reduced. I identify every available basis for penalty relief and pursue it aggressively.