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David K. Petzinger, Esq.

David not only earned his Juris Doctor from the University of Idaho, he also earned an LL.M. in Taxation (this is a post-doctorate Master's Degree) from the University of Washington. He holds a license in good standing with the Supreme Court of the State of Washington. David Petzinger has never been disciplined by the Washington Bar Association.Prior to joining Fortress, David worked for the prestigious Seattle law firm, K & L Gates, where he was involved with a variety of large civil litigation cases. He possesses polished negotiation and advocacy skills derived from his previous experience as a criminal defense attorney. David also gained experience representing taxpayers before the Internal Revenue Service and in United States Tax Court before he joined Fortress. David's education and experience in tax law coupled with his strong ability to negotiate make him a very effective advocate for taxpayers facing America's most formidable creditor-the Internal Revenue Service.

Your Rights as a TaxPayer

“A wise and frugal government, which shall leave men free to regulate their own pursuits of industry and improvement, and shall not take from the mouth of labor the bread it has earned — this is the sum of good government.” Thomas Jefferson, First Inaugural Address, 1801 There is a tad bit more government in …

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Top Five Ways to Release IRS Levy

Top 5 Ways to Get an IRS Tax Levy Released

If you have had the misfortune of experiencing an IRS levy then you have experienced the feeling of dread when looking at your bank account’s zero balance and no way to pay that month’s bills.  You may also know how hard it can be to get a levy released.   Below are top five basic strategies …

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What Can The IRS Do To Me?

IRS Threats: What Can They Really Do to Me?

I hear from my clients at times that an IRS Revenue Officer (tax collector) told them they could lose their house, they could be sued, their retirement and 401k will be taken, wages can be garnished, and a whole bunch of other awful scenarios.   These types of threats keep people up at night and are …

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Stop Federal Tax Levy

How to Avoid the Dreaded Federal Payment Levy Program

Federal Payment Levy Program If you or your business has unpaid federal taxes and you receive income or revenues from the federal government or an agency of the federal government, watch out!  You could be in for a rude awakening when the IRS and Treasury Department team up to keep monies that are due to …

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Accrual Method of Accounting | Installment Agreement | TaxFortress.com

Cash And Acurral Methods Of Accounting Can Impact The Outcome Of A Tax Collection Case

To some business owners, the accounting part of their business is the last thing they want to deal with.  “Leave that to the accountant or bookkeeper and let me get to work” is the sentiment I get from a lot of small business owners. Accrual Method of Accounting Many business owners just don’t have the …

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IRS Automated Collection System | IRS Revenue Officer | TaxFortress.com

IRS Automated Collection System (“ACS”) vs. Revenue Officer: What’s the Difference?

When an IRS tax liability goes to collections, it will either be assigned to the IRS Automated Collection System (“ACS”) or to the Collection field function, where a Revenue Officer will be assigned and charged personally with attempting to collect the unpaid tax.  Some delinquent accounts will initially be assigned to ACS only to be …

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What is an IRS Tax Lien | Notice of Federal Tax Lien | TaxFortress.com

What Is An IRS Tax Lien And How Does It Affect Me?

Federal IRS Tax Lien An IRS Tax Lien is a legal claim on your property for the amount owed. An IRS tax lien is also the legal right to collect on the amount owed. An IRS Tax lien starts when a tax is assessed and you don’t pay it. For example, if you file a …

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Fraudulent Tax Return | IRS Fraud | Identity Theft | TaxFortress

Identity Theft and the IRS – Beware of Identity Thieves Stealing “Your” Tax Refund

You’ve been overpaying your taxes all year long, saving money in your IRS ‘refund account’ with the expectation that you will get that big fat juicy refund early next year. You get some software and prepare your own return or hire a tax preparer exclaiming big money is waiting for you. That vacation is just …

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S Corporation | Penalty Abatement | S Corp | TaxFortress

Exploring the Consequences of Paying S Corporation Shareholders Unreasonably Low Wages

If you are a shareholder in an S Corporation and you also work for that S Corporation, it is critical that that you pay yourself a reasonable wage. Many S Corporation owners take little or no compensation in the form of wages and, instead, disproportionately pay themselves in the form of distributions. This can lead …

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IRC 6331 | Innocent Spouse | Joint Bank Account | TaxFortress

Will The IRS Pursue Collection From My Spouse?

The answer to this question will depend on whether the liability is a joint liability or separate liability and whether you live in a community property state or not. If the IRS liability is a JOINT liability then YES, the IRS may levy both your and your spouse’s wages, assets, and/or accounts.  When it comes …

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