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David M. Feldman, Esq.

David holds a Bachelor's Degree in Business Economics with an emphasis in Accounting from the University of California at Santa Barbara. In addition, David holds a Juris Doctor degree from Lewis and Clark School of Law as well as an LL.M. (master's degree) in Taxation from the University of San Diego School of Law. He holds a license in good standing with the Supreme Court of the State of Oregon. David Feldman has never been disciplined by the Oregon Bar Association. Prior to joining Fortress, David fought for taxpayers in collections with the IRS while working for a Low-Income Legal Tax Clinic located in downtown Portland, Oregon. It was here that he gained valuable experience representing taxpayers before the Internal Revenue Service, and developed outstanding tax-related negotiation and advocacy skills. David helped settle multiple tax liabilities for a fraction of his clients' debts before joining the team of tax professionals at Fortress. David's professionalism combined with his advanced tax-related education and front-line experience in tax negotiations have predictably translated into great things for his clients--most notably, protection from enforcement and many extremely favorable results.

941 Tax | IRC 6672 | Trust Fund Recovery | TaxFortress

Can I Be Held Personally Liable for My Corporation or LLC’s Unpaid 941 Employer Withholding Taxes?

Can I be held personally liable for unpaid 941 employer withholding taxes?  What can be done to avoid this/protect personal assets/income? If you are an owner or officer of a corporation or LLC that has unpaid 941 employer withholding taxes and think that you’re personally off the hook because of your “corporate veil,” think again.  …

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Default on Tax Resolution with IRS

How to Avoid Defaulting an IRS Tax Resolution Agreement

Resolving a serious tax liability, whether by way of an Installment Agreement, Offer in Compromise (OIC), or Currently Not Collectible Status, is often a painstakingly difficult, time-consuming, and stressful process.  So, the last thing anyone who survives this process needs is to wind up defaulting their agreement.  It’s really bad news.  Not only will the …

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Default IRS Installment Agreement

Defaulted IRS Installment Agreement (CP523)

The CP523 notice of intent to levy intent to terminate your installment agreement is more or less saying that the agreement is in default and may terminate in 30 days.  If the agreement does terminate, involuntary enforced collection action will commence.  This could mean garnished wages, levied accounts receivable or levied bank accounts.  This could …

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5 Must-Knows About Personal Liability for Unpaid Employment Taxes (Trust Fund Recovery Penalty)

Are you an owner or employee of a business that is delinquent with employment taxes?  If so, watch out!  It is possible that you will be held personally liable for what is called the Trust Fund Recovery Penalty. What is the Trust Fund Recovery Penalty? In short, the Trust Fund Recovery Penalty is a penalty …

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45 Day Rule | Notice of Federal Tax Lien | IRC 6323 | TaxFortress

Understanding the IRS 45 Day Rule for a Federal Tax Lien

Many businesses rely on the use of their accounts receivable or inventory as collateral for loans or for factoring. However, in my experience, few business owners fully grasp how devastating the consequences can be if they engage in this type of financing and fall behind with federal taxes. Unfortunately, fully grasping this concept often does …

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6 Reasons for Payroll Outsourcing | 941 Employment Tax Liability

Six Reasons for Payroll Outsourcing

As an attorney who makes his living resolving tax liabilities, the majority of my clients are businesses that have accrued 941 employment tax liability.  There are numerous reasons as to why a business accrues a 941 tax liability.  These reasons range from mere lack of funds resulting from both internal and external issues to simply …

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Third Party Liability | Transferee Liability | TaxFortress.com

Understanding IRS Successor, Alter Ego , Nominee, And Transferee Liability

You invested your entire savings and better part of your working life into your business in an attempt to have it succeed and ultimately grow.  During this time many unforeseen obstacles occurred that caused you to have to make difficult decisions, one of which was to forego making a tax deposit in order to remit …

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Tax Compliance & Eligibility | Installment Agreement | Offer in Compromise

Tax Compliance – What You Need to Know to Become Eligible for an IRS Installment Agreement

In order to be eligible to resolve an outstanding federal tax liability on a voluntary basis (e.g. Installment Agreement, Offer in Compromise), as opposed to having it forcefully resolved through collection action such as levies, garnishments, and the seizure of assets, the IRS has two basic requirements. The first requirement is that you are in …

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Innocent Spouse Relief | Separation of Liability Relief | Equitable Relief

Innocent Spouse Relief Can Relieve Your Spouse of a Joint IRS Liability

If the IRS is pursuing collection action against you for an income tax liability for which you believe you are not responsible because the liability was derived from a spouse (or former spouse), you may be correct and have legal grounds to dispute the liability. The IRS has a specific provision called innocent spouse relief …

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IRS Penalty Relief | Tax Penalty | Penalty Abatement

IRS Tax Penalties: Is it Possible to Eliminate My Tax Penalties?

It is possible for some taxpayers to reduce or eliminate their IRS tax penalties by obtaining an abatement of penalties.  This article will explore the fundamentals of IRS penalties as well as how to go about getting them removed.  Taxpayers with a state tax liability may also qualify for an abatement, depending on the state.  …

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IRS Garnishment | Will The IRS Garnish My Wages | IRS Levy

Will the IRS Garnish My Wages?

Question:  Will the IRS garnish my wages or Levy my wages? How can I avoid this? Answer: In order to answer this question effectively, some background and definitions with regards to IRS procedures are warranted.  A levy on wages is where the IRS effectively takes a portion of ones wages and applies it to the …

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