The IRS lost about a quarter of its workforce. The penalties did not.

When letters go unanswered for months and interest keeps running, you do not need a hand to hold. You need representation that knows the right channel, preserves your deadlines, and presses for a response.

The IRS that exists today is not the agency most taxpayers remember. Its workforce fell by roughly a quarter in a single year, with the steepest cuts hitting enforcement and audit functions, while the staff who answer the phone and process correspondence were thinned out and only partly backfilled. The National Taxpayer Advocate has been blunt about the result. The burden has shifted to the taxpayer to make sure a matter is resolved correctly, on time, and on the record.

That shift is expensive for the unrepresented. Correspondence sits unworked for months while penalties and interest accrue. Deadlines pass that the agency will not remind you about. A case that should have closed in weeks becomes a year of silence.

We work that gap. Knopfler PLLC handles federal and New York State tax disputes the way we handle every matter at the firm: as litigation. We do not sell a back door to the IRS, because there is no such thing. We are the lawyers who know how to use the front door, even when it is understaffed, and who treat your deadlines as if they are the only ones that matter.

How We Help: Federal (IRS)

  • Audit and examination representation. We manage communications with the examiner, review every request, and make disciplined, legally appropriate productions.
  • Penalty abatement. Reasonable cause, first-time abatement, and challenges to penalties that should never have been assessed.
  • Offers in compromise and installment agreements. Realistic resolution of liabilities you cannot pay in full.
  • Liens and levies. Releases, withdrawals, subordinations, and collection due process challenges.
  • Trust fund recovery penalty and responsible person assessments. Defense against personal liability for unpaid payroll taxes.
  • Payroll tax disputes. Classification, assessment, and collection matters.
  • Appeals and escalation. We move stalled matters to the Office of Appeals and, where warranted, to the Taxpayer Advocate Service.
  • Unanswered notices. When the agency goes quiet, we build the record and use available escalation channels to press for a response.

How We Help: New York State

  • New York State tax warrants. Vacating, satisfying, and challenging warrants and the liens that follow them.
  • Sales tax audits. Including the responsible person liability that can reach owners and officers personally.
  • Residency and domicile audits. Statutory residency, domicile, and the day-count and recordkeeping fights that decide them.
  • Convenience of the employer disputes. Remote and hybrid worker sourcing questions for New York income.

The Approach

A tax controversy is a dispute with a government adversary, a record, and deadlines that do not forgive. That is litigation, and it is what this firm does. You work directly with the attorneys handling your matter. There is no layer of associates between you and the people making the decisions, and no question about who is accountable for the outcome.

If you have received a notice you do not understand, an assessment you believe is wrong, or silence where a resolution should be, the cost of waiting is measured in penalties and interest. Earlier is cheaper.

This is defense after a dispute has started. If your goal is to structure entities, transactions, and residency to keep disputes from arising in the first place, see our Tax Planning practice.

Common Questions

Why is the IRS taking so long to respond in 2026?

The IRS lost about a quarter of its workforce over the past year, and the units that run audits and enforcement absorbed the steepest cuts, while the staff who answer calls and process correspondence were reduced and only partly backfilled. The practical result is that routine matters that once took weeks now sit for months. Penalties and interest do not pause while your file waits, so the burden has shifted onto you to push your matter forward and protect your own deadlines.

How do I get IRS penalties removed?

The two main routes are first-time abatement, for taxpayers with a clean recent compliance history, and reasonable cause relief, where circumstances outside your control caused the failure. You request abatement in writing or by phone, supported by facts and documentation. When a penalty is reduced or removed, the statutory interest may also be reduced or removed as long as it is related to that penalty. Interest on the underlying unpaid tax, however, is different and normally continues until paid. First-time abatement is an administrative waiver limited to the failure-to-file, failure-to-pay, and failure-to-deposit penalties. It is not available for accuracy-related, estimated-tax, or fraud penalties. It generally requires that you have filed the same type of return, if required, for the prior three tax years, have filed or extended all current returns and paid or arranged to pay any tax due, and had no disqualifying penalties during that three-year compliance period.

What is an Offer in Compromise, and do I qualify?

An Offer in Compromise lets you settle a federal tax debt for less than the full amount when you cannot pay in full and the IRS agrees the offered amount reflects your reasonable collection potential. There are threshold rules first: you must be current on required filings and on estimated payments or federal tax deposits, and a taxpayer in an open bankruptcy generally cannot submit one. If those are met, eligibility turns on your income, expenses, assets, and future earning capacity, not on a hardship narrative alone. Many people who ask about an offer are better suited to another collection alternative, so the financial analysis has to be right before you file. An offer is submitted on the Form 656 booklet with Form 433-A (OIC) and/or Form 433-B (OIC), or online where the IRS allows it, with a $205 application fee unless you qualify for the low-income waiver, which can also waive the initial payments. One caution that is easy to miss: filing an offer suspends the 10-year collection clock while the IRS reviews it, so a rejected offer can leave the agency more time to collect than it had before you filed.

Can the IRS take my home, wages, or bank account?

Yes, through a levy, but generally only after it has sent notice and given you the chance to respond. Before most levies the IRS must issue a Final Notice of Intent to Levy and inform you of your right to a Collection Due Process hearing, which you can request within a limited window. Acting inside that window is often the difference between stopping a levy and reacting after the funds are gone. The request window is generally 30 days from the date printed on the face of an LT11 or Letter 1058, not the date you get around to opening the envelope. Missing that window can drop you to an equivalent hearing and cost your right to Tax Court review, so act fast.

Can I be personally liable for my business's unpaid New York sales tax?

Yes, and the New York standard is harsher than the federal one. Unlike the federal trust fund penalty, which requires a showing of willfulness, New York imposes personal liability on a responsible person for sales tax the business collected and failed to remit without any willfulness requirement, under NY Tax Law §§ 1131(1) and 1133(a). Owners, officers, and others under a duty to collect and remit can be reached individually, and corporate title alone can create exposure. Certain minority LLC members and limited partners may qualify for partial relief, but the exposure is serious and fact-specific.

Source: NY Tax Law §§ 1131(1), 1133(a)

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Attorney Advertising. Prior results do not guarantee a similar outcome. The information on this page is provided for general informational purposes only and does not constitute legal or tax advice. Tax deadlines and remedies depend on the specific notice, tax period, procedural posture, and facts, and the figures and rules described here can change; do not rely on this page as a substitute for advice about your own matter. Reading this page or contacting the firm does not create an attorney-client relationship; that relationship is formed only by a signed engagement agreement. Workforce and operational figures cited regarding the Internal Revenue Service are drawn from public reporting by the National Taxpayer Advocate and are current as of the date of publication.