You Got The Letter.
Now You Need A Plan.
An IRS audit notice, a CP2000, a Florida sales tax assessment, or a lien doesn't resolve itself — and waiting turns a fixable problem into a frozen account or a garnished paycheck. Connect with a Miami tax attorney who can pull your IRS transcripts, lay out your options, and deal directly with the IRS or the Florida Department of Revenue on your behalf.
Federal & Florida Tax Law
Deadlines Decide
Everything. Know Yours.
Every tax problem runs on a clock — how far back the IRS or the state can dig, how long the government has to collect, and how many days you have to respond before your options narrow. Knowing which clock applies to you is the first move.
The IRS generally has three years from when you filed to audit a return — six years if more than 25% of your gross income was left off, and no limit at all if a return was never filed or was fraudulent.
Once the IRS assesses a tax debt, it generally has ten years to collect it through liens, levies, or wage garnishment — a deadline that can be paused by bankruptcy, an Offer in Compromise, or other actions.
The Florida Department of Revenue generally has three years to assess sales, use, or other state taxes — with no limit if a required return was never filed or a fraudulent return was submitted.
"A tax notice isn't a verdict — it's a deadline. What you do before it passes decides what happens next."
Where Tax Problems Start
The Notice.
The Deadline.
The Response.
Tax problems in Miami come from a handful of recurring sources — a federal audit, a state assessment, or a local property valuation. Each runs on its own rules and its own clock.
IRS Audits & CP2000 Notices
Correspondence audits, office audits, and automated underreporter notices that flag a mismatch between what you filed and what the IRS has on record.
Unfiled Back Tax Returns
Years of unfiled returns don't start any statute of limitations running — the IRS can act on them at any time, and the longer they sit, the more penalties and interest accrue.
IRS Collections — Liens, Levies & Garnishment
Once a balance is assessed, the IRS can file a federal tax lien, levy a bank account, or garnish wages if a payment plan or resolution isn't already in place.
Florida Sales & Use Tax Audits
The Florida Department of Revenue routinely audits restaurants, retailers, and service businesses on sales tax collection and remittance, often reaching back several reporting periods.
Property Tax Assessment Disputes
An inflated TRIM notice valuation can be challenged with the county Value Adjustment Board — but the filing window is short and strictly enforced.
Payroll & Trust Fund Tax Issues
Unpaid payroll withholding can expose a business — and the individuals responsible for paying it — to the IRS's Trust Fund Recovery Penalty.
Is This You?
A Consultation Might
Make Sense If You...
There's no single type of tax problem that qualifies for a conversation — these are some of the more common situations Miami-area tax attorneys hear about first.
You received an IRS audit or CP2000 notice
A letter proposing changes to a filed return, or requesting documentation to support what you reported.
You haven't filed tax returns in a year or more
Whether it's one missed year or several, unfiled returns keep the IRS's clock from ever starting.
You have a federal tax lien or a bank levy
The IRS has already taken collection action, or has warned that it's about to.
You got a Florida DOR sales tax assessment
A notice of proposed assessment following a state audit of your business's sales tax records.
Your TRIM notice valuation looks inflated
The assessed value on your property tax notice doesn't match what comparable properties are worth.
Your business owes payroll or withholding tax
Unpaid trust fund taxes that could expose the business — and potentially you personally — to penalties.
How It Works
From the Notice
to a Resolved Matter.
Tax matters move on the government's clock, not yours — but the process of responding to them follows a clear sequence.
Free Case Review
A connected Miami tax attorney reviews your notice or situation, the taxing authority involved, and where you stand on the relevant deadline.
Transcripts & Records Review
IRS account and wage transcripts, or Florida DOR audit workpapers, are pulled and reviewed to confirm exactly what's owed and why.
Response & Negotiation
A protest, an Offer in Compromise, an installment agreement, or a formal reply to the taxing authority is prepared and negotiated on your behalf.
Resolution or Formal Appeal
If a resolution isn't reached, your attorney can petition Tax Court, file with DOAH, or take a valuation dispute to the Value Adjustment Board within the applicable deadline.
From People We've Worked With
What They Say
"I'd ignored the audit letter for months out of pure dread. Having someone explain what it actually meant took the panic out of it."
"The Department of Revenue kept calling about the sales tax assessment. Once I had representation, all of that went through my attorney instead."
"I knew exactly what the timeline looked like at every step — no surprises, no last-minute scramble before a deadline."
Common Questions
What You Need to Know
Generally three years from when you filed, under 26 U.S.C. §6501(a). That window extends to six years under §6501(e) if you omitted more than 25% of your gross income, and there's no time limit at all under §6501(c) if a return was never filed or was fraudulent. A connected Miami tax attorney can review your filing history at no cost.
Generally ten years from the date of assessment, under 26 U.S.C. §6502. That collection clock can be paused — and effectively extended — by events like bankruptcy, a pending Offer in Compromise, or a Collection Due Process request. A connected attorney can map out where your clock actually stands.
Under Fla. Stat. §95.091(3)(a), the Florida DOR generally has three years after the tax was due, a return was due, or a return was filed — whichever is later — to assess sales, use, or other state taxes it administers. There's no deadline if a required return was never filed or a fraudulent return was submitted. Talk through your audit notice with a connected attorney.
Under Fla. Stat. §194.011(3)(d), you generally have 25 days from the mailing of your TRIM notice to file a petition with your county's Value Adjustment Board. Disagree with the VAB's decision, and Florida law generally gives you 60 days from that decision to take the matter to circuit court — a deadline courts treat strictly. Start the conversation now so your window doesn't close.
Under 26 U.S.C. §6213(a), you generally have 90 days from the date the notice was mailed (150 days if addressed outside the United States) to petition the U.S. Tax Court for a redetermination. Missing that window generally means the IRS can assess the proposed deficiency without further recourse in Tax Court.
No — Florida is one of a small number of states with no individual state income tax. That doesn't mean Florida residents are free of state-level tax exposure: Florida still imposes sales and use tax, a corporate income tax on C-corporations, and property tax administered at the county level, each with its own audit and appeal process.
You Have A Deadline.
Find Out What It Is.
A confidential case review about your IRS or Florida tax situation — no pressure, no obligation.