I.R.S. Disputes
Since 1987, Mr. Crowgey has amassed considerable experience in the practice area of federal and state tax controversies, audits, and
appeals, particularly federal and state tax collection actions and collection due process appeals. With the passage of the 1998 Internal
Revenue Service Restructuring Act, there were a great many tools created by Congress to allow attorneys to level the playing field on behalf of
tax clients.
Mr. Crowgey has the distinction of litigating successfully Collection Due Process Appeal cases in the United
States Tax Court, Harrell v. Commissioner of Internal Revenue, T.C. Memo 2003-271 (September 17, 2003); rehearing denied, T.C. Memo
2003-312 (November 12, 2003). As well, Mr. Crowgey successfully litigated with the IRS and obtained a portion of his legal fees back from the IRS on behalf of his client.
United States of America v. Ronald I Stallings, Dianne N. Stallings, and Bank of America Corporation, June 2006, United States District Court for the District of South Carolina, Civil Action No.: 4:05-cv-03143-TLW; nominee liens filed against taxpayer for ex-husband’s $180,000+ income tax liability; dismissed with all tax liens being released on client’s property, and the Internal Revenue Service paying client back $23,000.00 in legal fees incurred.
Stanislas, et. al. adv. United States of America; 2008; United States District Court for the Eastern District of Virginia, Richmond Division, Civil Action No.: 3:07cv393; federal tax lien case to foreclose over $800,000 in federal income taxes extending over 10 years against the taxpayers’ 4 properties in Petersburg, resulting in concession of over $300,000 in settlement of all issues between the Federal Government and the taxpayers voluntary sale of houses in complete release of any and all claims against the taxpayers.
C-A--, Jr. v. IRS, 2006, Civil Trust Fund penalty of over $450,000; former board member for 11 years at a local recycling plant; resulting in abatement of all prior assessments except for two quarters totaling $45,000 and repayment of same.
Merriman v. Comm’r., May 2006, United States Tax Court Docket #5245-05S; original assessment $145,000.00; resulting tax, penalty and interest due $5,500.00.
Colburn v. Comm’r, November, 2005, United States Tax Court Docket #12124-04; original assessment $150,000.00; resulting tax, penalty and interest due $8,400.00.
In addition to collection due process appeal rights, which give tax practitioners the ability to stay the enforcement of federal tax levies and
appeal the filing of federal tax liens, there are numerous other tools available to the tax practitioner. These include more liberal innocent spouse
relief, contribution for joint and several tax liabilities, mandatory installment agreement procedures, streamlined Offer in Compromise
procedures, subordination and withdrawal of federal tax liens, as well as a variety of federal and state remedies too numerous to detail or
mention here.
Mr. Crowgey enjoys an extremely good working relationship with the Internal Revenue Service appeals and collection branches both in the
Richmond and Hampton Roads areas. We also have excellent working relationships with local Revenue Officers, Group Managers, Territory
Managers, and the Area Manager for the SBSE Division, as well as with the local and national Taxpayer Advocate Office and the Criminal
Investigation Division.
If you suspect that your audit, appeal, civil or criminal tax rights may have been violated,
we would welcome the opportunity to meet with you
to review the possible options and discuss our possible engagement.
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