Encountering an IRS revenue officer can be a stressful experience, especially if you’re unfamiliar with their role and the potential implications of their visit. Understanding how to deal with a revenue officer effectively can make a significant difference in the outcome of your situation. Here’s a comprehensive guide to help you navigate this challenging scenario.
What is an IRS Revenue Officer?
An IRS revenue officer, or RO, is a field agent tasked with collecting unpaid taxes from individuals, businesses, and self-employed professionals. Unlike revenue agents, who conduct audits, revenue officers are primarily focused on securing payment for tax debts, often dealing with more severe cases where substantial amounts are owed or where there has been a history of non-compliance.
Revenue officers have the authority to take serious collection actions, including levying bank accounts, garnishing wages, and placing liens on property. Because of this, knowing how to interact with them is crucial.
Steps to Take When a Revenue Officer Contacts You
When dealing with an RO, it’s important to remember some key details. Here are some steps to take when a revenue officer contacts you.
Stay Calm and Professional
The first and most important step is to remain calm. Revenue officers are doing their job, and while their presence can be intimidating, maintaining a professional demeanor can prevent escalation and help you manage the situation more effectively.
Verify Their Identity
Always verify the identity of the revenue officer. They should provide you with an ID badge that includes their name, photo, and IRS identification number. You can also call the IRS at 1-800-829-1040 to confirm their legitimacy.
Understand the Scope of the Visit
Revenue officers may visit you at home or at your place of business. However, note that ROs are no longer allowed to conduct surprise visits. This decision came in 2023 to help taxpayers avoid scammers posing as the IRS to collect money. Remember, an RO’s goal is to collect unpaid taxes or ensure compliance with tax laws. During the initial visit, they will likely ask questions about your financial situation and may request documentation. Be clear about the purpose of their visit and ask for a detailed explanation if needed.
Do Not Provide Information Immediately
While you should cooperate with the revenue officer, it’s wise not to provide too much information during the initial meeting. Politely inform them that you need time to review their requests and consult with a tax professional. This can help prevent you from inadvertently sharing information that could complicate your case.
Consult a Tax Professional
One of the best steps you can take is to consult with a tax professional, such as an enrolled agent, tax attorney, or CPA, before providing detailed information to the revenue officer. A professional can help you understand your rights and obligations and assist in developing a strategy to resolve your tax issues.
Review Your Financial Situation
Before meeting with the revenue officer again, take the time to thoroughly review your financial situation. Gather all relevant documents, including tax returns, bank statements, and records of income and expenses. Understanding your financial position will help you negotiate effectively.
Negotiate Payment Arrangements
If you owe taxes, you may be able to negotiate a payment arrangement with the revenue officer. Options include installment agreements, offers in compromise, or temporarily delaying collection with CNC status if you’re facing financial hardship. Your tax professional can assist in these negotiations to ensure you get the best possible terms.
Keep Records of All Communications
Document all interactions with the revenue officer, including phone calls, meetings, and any correspondence. This record-keeping is crucial in case disputes arise or if you need to reference past agreements.
Understand Your Rights
You have rights when dealing with an IRS revenue officer. For example, you have the right to be treated fairly, to privacy, and to representation. The Taxpayer Bill of Rights outlines these protections, and being aware of them can empower you during the process.
Respond Promptly
Ignoring a revenue officer or failing to respond to their requests can lead to more severe collection actions. Even if you’re unable to pay the full amount owed, communicate with the officer and work towards a resolution.
Tax Help for Those Dealing with an RO
Dealing with an IRS revenue officer can be challenging, but with the right approach, you can navigate the process effectively. By staying calm, verifying their identity, consulting with a tax professional, and understanding your rights, you can work towards resolving your tax issues while minimizing stress and potential financial repercussions. Remember, proactive and informed actions are key to successfully managing your interactions with a revenue officer. Optima Tax Relief is the nation’s leading tax resolution firm with over a decade of experience helping taxpayers with tough tax situations.
One of the most severe actions the IRS can take against you is issuing a wage levy. A wage levy allows the IRS to seize a portion of your paycheck directly from your employer, leaving you with a reduced income until your debt is paid off. Understanding how wage levies work, the process involved, and your rights can help you navigate this difficult situation more effectively.
What Is an IRS Wage Levy?
An IRS wage levy, also known as a wage garnishment, is a legal action that allows the IRS to collect unpaid taxes directly from your wages. Unlike a wage garnishment initiated by a creditor, an IRS wage levy does not require a court order. Once the IRS issues the levy, your employer is required by law to withhold a significant portion of your paycheck and send it directly to the IRS.
How Does the Wage Levy Process Work?
The IRS doesn’t issue a wage levy without warning. The process typically follows these steps:
Notice and Demand for Payment. The IRS will first send you a notice, known as a “Notice and Demand for Payment.”. This tells you how much you owe and is your opportunity to resolve the debt voluntarily.
Final Notice of Intent to Levy. If you fail to respond to the initial notice, the IRS will send Notice CP90, which is a “Final Notice of Intent to Levy and Notice of Your Right to a Hearing” at least 30 days before the levy is issued. This notice gives you a final opportunity to resolve the debt or request a hearing.
Issuance of Levy. If you do not act within the 30-day period, the IRS will issue the wage levy to your employer. Your employer must then begin withholding a portion of your wages.
How Much Can the IRS Take from Your Paycheck?
The amount the IRS can take from your paycheck is based on the standard deduction and the number of dependents you claim. The IRS sends Publication 1494 along with the levy to your employer. This instructs your employer on how to calculate the amount exempt from the levy. Your employer will give you a Statement of Dependents and Filing Status that you must complete and return within three days. If you don’t return the statement within this period, your exempt amount will be calculated as if you’re married filing separately with no dependents (zero). If you have multiple income sources, the IRS may assign the exemptions to those other sources and levy 100% of the income from a specific employer.
Any amount above the exempted portion can be levied. For many, this can result in a substantial reduction in take-home pay. Let’s look at some examples. Let’s say you are a single filer with no dependents with weekly gross pay of $1,000. Your weekly exempt amount is around $281. This means the IRS can levy $719 from each paycheck. Now, let’s say you are a single parent of one child who files as Head of Household and has weekly gross pay of $2,000. Your weekly exempt amount is around $517. This means the IRS can levy $1,483 from each paycheck. For someone married filing jointly with two dependents and gross weekly pay of $1,500, the weekly exempt amount might be around $754. The IRS can levy $746from each paycheck.
Will the IRS Levy My Bonuses?
When a wage levy is in place, it generally applies to any regular wages, salary, and other forms of compensation, including bonuses. This means that if you receive a bonus while under an IRS wage levy, the IRS will take the entire bonus.
What If I Pay Child Support?
If you pay child support directly, rather than through wage withholding by an employer, it’s crucial to take extra steps to protect your obligations if you’re subject to an IRS wage levy. Unlike wage withholding for child support, which is typically prioritized over IRS levies, direct payments may not automatically receive the same protection. In this situation, you should immediately notify the IRS of your child support obligations and provide documentation, such as court orders, to demonstrate your required payments. You may be able to negotiate with the IRS to adjust the levy amount or even secure a release from the levy to ensure that your child support payments continue uninterrupted. Consulting with a tax professional can also help you navigate this process and safeguard your responsibilities.
What Are Your Rights?
Even though an IRS wage levy is a serious matter, you still have rights. First and foremost, you have the right to notice. The IRS must notify you in advance of its intent to levy your wages, giving you a chance to resolve the debt or appeal the decision. Next, you have the right to appeal through a Collection Due Process (CDP) hearing within 30 days of receiving the final notice. This hearing allows you to dispute the levy or negotiate alternative payment arrangements.
You also have the right to payment arrangements. Even after a levy is issued, you may be able to negotiate an installment agreement or an offer in compromise, which could result in the levy being released. Finally, you have the right to hardship consideration. If the wage levy causes significant financial hardship, you can request that the levy be released. The IRS may consider your financial situation and decide to release the levy, although you will still owe the tax debt.
How to Avoid a Wage Levy
The best way to avoid a wage levy is to address your tax debt early. If you receive a notice from the IRS, don’t ignore it. Pay the full amount you owe to avoid further action if possible. If you can’t pay the full amount, consider setting up a payment plan with the IRS. In some cases, the IRS may accept a lower amount than what you owe if you can demonstrate that paying the full amount would create financial hardship. Tax professionals can help you negotiate with the IRS and explore options that you may not be aware of.
Tax Help for Those Being Levied by the IRS
An IRS wage levy can have a significant impact on your finances, but understanding the process and your rights can help you manage the situation. If you receive a notice of a potential levy, take action immediately to explore your options and avoid further financial strain. Whether through payment arrangements, appealing the levy, or seeking professional assistance, there are ways to resolve your tax debt and minimize the impact on your income. Optima Tax Relief is the nation’s leading tax resolution firm with over $3 billion in resolved tax liabilities.
When it comes to unpaid taxes, the IRS has powerful tools at its disposal to collect the debt. Among these tools is the ability to seize your assets, including your car. But under what circumstances can the IRS actually take your vehicle, and what can you do to protect yourself? Here’s what you need to know.
Understanding Tax Levies
A tax levy is a legal seizure of your property to satisfy a tax debt. Unlike a tax lien, which is a claim against your property as security for the tax debt, a levy actually takes the property to pay off the amount owed. The IRS can levy various assets, including bank accounts, wages, and personal property like cars, boats, or real estate.
When Can the IRS Seize Your Car?
The IRS doesn’t take the decision to seize property lightly. They typically resort to this measure only after several attempts to collect the tax debt have failed. Here are the general steps the IRS must follow before they can take your car:
Notice of Demand for Payment: The IRS will first send you a notice demanding payment. This is a formal request to pay the outstanding tax debt.
Final Notice of Intent to Levy: If you don’t respond to the demand for payment, the IRS will send a Final Notice of Intent to Levy and Your Right to a Hearing at least 30 days before they move forward with the levy. This notice gives you a final chance to settle the debt or appeal the levy action.
Collection Due Process Hearing: You have the right to request a Collection Due Process (CDP) hearing within 30 days of receiving the final notice. This hearing allows you to challenge the levy or negotiate a payment plan.
Asset Seizure: If you don’t respond to the final notice or if your appeal is unsuccessful, the IRS can proceed with the levy. They may choose to seize assets, including your car, to satisfy the tax debt.
Factors the IRS Considers
Before seizing your car, the IRS will consider several factors:
Value of the Car: The IRS will evaluate whether the value of your car exceeds the amount of the debt. They are unlikely to seize a car if the costs of seizing and selling it (such as towing, storage, and auction fees) are greater than the proceeds that would be applied to the debt.
Your Need for the Car: The IRS may consider whether the vehicle is necessary for your livelihood. For example, if you need the car to get to work, the IRS might decide not to seize it, though this is not guaranteed.
Other Available Assets: The IRS will typically look at other assets you own before seizing a vehicle. If you have other property or accounts that can be levied more easily or without as much hardship, they may opt for those first.
What Can You Do to Protect Your Car?
If you’re facing potential asset seizure by the IRS, there are steps you can take to protect your car and other property:
Communicate with the IRS: The worst thing you can do is ignore IRS notices. Communicate with them and try to work out a payment plan or settlement.
Request a Collection Due Process Hearing: If you receive a Final Notice of Intent to Levy, promptly request a CDP hearing. This can temporarily halt the levy process and provide an opportunity to negotiate.
Seek Professional Help: Consider hiring a tax professional, such as a tax attorney or enrolled agent, who can negotiate with the IRS on your behalf and help protect your assets.
Consider an Offer in Compromise: If you can’t pay the full amount, you might be able to settle your tax debt for less than what you owe through an Offer in Compromise (OIC).
Tax Help for Those Who Owe
Yes, the IRS can seize your car to satisfy a tax debt, but it’s typically a last resort after other collection efforts have failed. By understanding your rights and responding to IRS notices, you can take steps to protect your property and resolve your tax issues before they escalate to the point of asset seizure. If you find yourself in this situation, it’s crucial to act quickly and seek professional advice to navigate the complexities of dealing with the IRS. Optima Tax Relief has over a decade of experience helping taxpayers get back on track with their tax debt.
The IRS plays a critical role in ensuring that taxpayers comply with U.S. tax laws. Within the IRS, various professionals are tasked with different responsibilities, including revenue officers and revenue agents. While these roles may sound similar, they have distinct functions and purposes within the IRS. Understanding the difference between an IRS revenue officer and a revenue agent can be crucial for taxpayers who find themselves dealing with the agency.
Role and Responsibilities
The true difference between an IRS revenue officer and a revenue agent lies within their roles and responsibilities.
Revenue Officer
A revenue officer is a field agent responsible for collecting unpaid taxes from individuals and businesses. Their primary role involves enforcing tax laws and ensuring that taxpayers fulfill their obligations to pay taxes. Revenue officers are tasked with collecting delinquent tax debts and securing tax returns that have not been filed. They often work directly with taxpayers in person, visiting homes or businesses to resolve issues related to tax collection.
Key responsibilities of a revenue officer include:
Collecting unpaid taxes and securing delinquent tax returns.
Enforcing tax compliance through levies, liens, or seizures of assets.
Working with taxpayers to set up payment plans or offer in compromise.
Investigating and locating assets to satisfy tax debts.
Ensuring that employers comply with employment tax requirements.
Revenue officers often handle more complex and severe cases where taxpayers have not responded to previous IRS notices or have significant unpaid tax liabilities. Their work can sometimes involve confrontation, as they have the authority to take drastic enforcement actions if necessary.
Revenue Agent
A revenue agent, on the other hand, is primarily focused on auditing taxpayers to ensure accurate reporting and compliance with tax laws. Unlike revenue officers, revenue agents do not focus on tax collection but rather on the verification of tax returns. They conduct examinations of individual and business tax returns to determine if the reported income, expenses, and deductions are accurate and compliant with tax laws.
Key responsibilities of a revenue agent include:
Conducting audits of individual and business tax returns.
Reviewing financial records, books, and other documentation to verify tax return accuracy.
Assessing additional taxes owed based on discrepancies found during audits.
Providing guidance to taxpayers on how to correct errors and avoid future issues.
Specializing in specific areas of tax law, such as international taxation or large corporate audits.
Revenue agents typically work with taxpayers who may have complex tax situations, including large businesses, corporations, or high-net-worth individuals. Their role is more analytical, focusing on the detailed examination of tax records rather than enforcement actions.
Authority and Enforcement Powers
Another key difference between revenue officers and agents is their level of authority and enforcement privileges.
Revenue Officer
Revenue officers have significant enforcement powers, enabling them to collect unpaid taxes. They can place liens on a taxpayer’s property, levy bank accounts and garnish wages, and seize assets, including property, vehicles, and other valuables. They can also summon taxpayers to provide documentation or appear for interviews. These enforcement powers make revenue officers one of the more intimidating figures within the IRS, as they have the authority to directly impact a taxpayer’s financial situation if taxes remain unpaid.
Revenue Agent
Revenue agents, while they do not have the same enforcement powers as revenue officers, have the authority to determine whether additional taxes are owed. They can propose changes to tax returns, leading to increased tax liabilities. They can also assess penalties and interest for underpayment of taxes and refer cases to revenue officers or the IRS Criminal Investigation division if they uncover significant fraud or evasion. The role of a revenue agent is more focused on the accurate calculation of taxes owed rather than direct collection. However, the findings of a revenue agent can lead to subsequent enforcement actions by revenue officers if unpaid liabilities are identified.
Interaction with Taxpayers
The level of interaction with taxpayers also differs for revenue officers and agents.
Revenue Officer
Revenue officers often engage in direct, face-to-face interactions with taxpayers. They may visit a taxpayer’s home or business to discuss unpaid taxes, gather information, and collect payments. These interactions can be stressful for taxpayers, especially when enforcement actions are imminent. However, revenue officers also work with taxpayers to set up payment plans or resolve tax debts through negotiation.
Revenue Agent
Revenue Agents generally interact with taxpayers through audits, which may take place in person, over the phone, or by correspondence. The audit process can vary in complexity, from simple correspondence audits handled by mail to more extensive field audits, where the revenue agent reviews records on-site. The interaction is usually more analytical and less confrontational than that of a revenue officer.
Impact on Taxpayers
Because of the level of authority, there is also a difference in the amount of impact these two figures hold on taxpayers.
Revenue Officer
The impact of a revenue officer on a taxpayer can be immediate and severe. If a taxpayer fails to cooperate or resolve their unpaid taxes, the revenue officer can take enforcement actions such as levies or asset seizures, which can have significant financial consequences.
Revenue Agent
The impact of a revenue agent is more related to the accuracy of tax reporting. An audit by a revenue agent can result in additional taxes owed, along with penalties and interest. However, revenue agents do not directly enforce collection, so the immediate financial impact may be less severe compared to that of a revenue officer.
Taxpayer Rights
When dealing with revenue officers and revenue agents, taxpayers have specific rights designed to protect them throughout the process. The IRS must inform taxpayers of these rights, including the right to be treated fairly, privacy, and representation. Taxpayers can seek the assistance of a tax professional, such as a certified public accountant (CPA), enrolled agent, or tax attorney, who can represent them in discussions with the IRS. Additionally, taxpayers have the right to appeal decisions made by revenue officers or revenue agents if they believe the IRS has made an error. Understanding and exercising these rights can help ensure that interactions with the IRS are conducted fairly and according to the law.
Tax Help for Those with a Revenue Officer or Agent
In summary, while both IRS revenue officers and revenue agents are critical to the functioning of the IRS, their roles, responsibilities, and impacts on taxpayers are quite different. Revenue officers are primarily involved in the collection of unpaid taxes and have significant enforcement powers. In contrast, revenue agents focus on auditing tax returns to ensure compliance with tax laws, with their work being more analytical and less enforcement driven. Understanding the distinction between these roles can help taxpayers better navigate their interactions with the IRS and take appropriate steps to address their tax obligations. Optima Tax Relief is the nation’s leading tax resolution firm with over a decade of experience helping taxpayers with tough tax situations.
It can be difficult and frustrating to deal with tax debt. You might be concerned about whether the IRS has the right to seize your assets if you owe taxes to them and haven’t taken steps to address the debt. Understanding which assets the IRS can seize is crucial for taxpayers, particularly those facing financial difficulties. Here’s a comprehensive overview of what the IRS can and cannot seize.
Can the IRS Seize My Assets?
The simple answer to this question is yes. The IRS can legally seize your assets to pay off a tax balance you owe. However, it is crucial to remember that the IRS normally views asset seizure as a last resort. Before initiating asset seizure, it is your taxpayer right to be notified. The IRS will make several attempts to collect the tax debt through IRS notices and other means before resorting to seizures. This is so you can attempt to correct the issue, perhaps with an installment agreement or offer in compromise. If you do not respond to IRS notices, they will impose a tax lien on your property. Only after this and a final warning will the IRS seize any assets.
Which Assets Can the IRS Seize?
Almost any item that has worth or equity and may be sold for cash can be seized by the IRS. Some of these assets can include:
Property
The IRS can place a lien on your property, such as your house or other real estate, establishing their legal claim to it. In some situations, they may seize and sell the property to recover the debt. However, seizing a primary residence is considered a last resort, and the IRS must go through a judicial process before doing so. The sale of the property typically occurs through a public auction, with the proceeds used to satisfy the tax debt.
Vehicles and Other Personal Assets
To satisfy your tax burden, the IRS may confiscate and sell your vehicles, boats, jewels, or other personal assets. However, the IRS typically considers the value of the vehicle and the amount of debt before deciding to seize it, as the cost of seizure and sale may not always justify the action.
Bank Accounts
The IRS can levy funds from your bank accounts to satisfy your tax debt. Bank levies are one-time only. This means the IRS can only take what is in the bank account now. You can deposit and withdraw funds from the account in the future. However, the IRS can always issue more levies in the future. The IRS typically notify you of this action, giving you a short window to contest the levy or arrange payment.
Retirement Accounts
The IRS has the legal authority to seize your 401(k) and other retirement savings, including self-employed plans. Although these accounts are shielded from creditors, the IRS has the legal right to confiscate funds from your retirement savings to recoup back taxes owed. However, certain rules and limitations apply, particularly regarding early withdrawal penalties and the protection of certain types of retirement accounts under federal and state laws.
Life Insurance
In certain cases, the IRS can even seize life insurance benefits, particularly if the policy has a cash surrender value. If you are the beneficiary of a life insurance policy and you owe the IRS, the IRS can seize those proceeds. Additionally, if you have a life insurance policy with no beneficiary named and you owe the IRS, the IRS can seize the policy funds before they are distributed to your next of kin.
Wages
The IRS has the authority to issue a wage garnishment, which means that they can legally order your employer to withdraw a percentage of your salary to pay off your tax debt. This can be a significant financial burden, as the levy continues until the tax debt is fully paid. The IRS also has the authority to seize other forms of income, including rental income, Social Security benefits, and even commissions. However, the IRS typically cannot seize the death benefit itself unless it has already been paid out and is part of the taxpayer’s estate. Additionally, term life insurance policies without a cash value are generally not subject to seizure.
Business Assets
For business owners, the IRS can seize business assets, including equipment, inventory, and accounts receivable. This can be devastating for a business, as it can disrupt operations and lead to financial instability. The IRS may also target the business’s bank accounts and income streams.
Which Assets Can the IRS Not Seize?
In general, any asset not necessary for your well-being and shelter (or the survival and shelter of your family) may be confiscated to pay the IRS what you owe. This can include:
Assistance provided by the Job Training Partnership Act
How Can I Protect My Assets from Being Seized by the IRS?
The good news is that an IRS asset seizure will never come as a surprise. Once you are aware that you owe the IRS, you should get to work on resolving the issue. However, we know that sometimes this isn’t always possible. You may have already received multiple IRS notices, and maybe one was an Intent to Levy. It’s not too late to get help from the nation’s leading tax resolution firm. Optima Tax Relief has over a decade of experience helping taxpayers with tough tax situations.
Dealing with an IRS levy can be incredibly stressful, especially when it creates a significant financial hardship. A levy allows the IRS to legally seize your assets, such as bank accounts, wages, and other property, to satisfy a tax debt. If this action is making it difficult to cover basic living expenses, it’s essential to know your options for relief.
Understand the Situation
First, ensure that the levy is, in fact, causing a hardship. A financial hardship is typically defined as a situation where the levy leaves you unable to meet basic, reasonable living expenses. These include things like rent, utilities, food, and medical costs. If you’re struggling to pay for these necessities due to the levy, you likely qualify for relief.
Request a Release of Levy
If you believe the levy is causing a hardship, you can request the IRS to release it. To do this, contact the IRS immediately. You’ll need to explain your situation and provide financial information to demonstrate that the levy is preventing you from meeting your basic needs.
You can contact the IRS at the number provided on your levy notice. Be prepared to discuss your financial situation in detail. Next, you’ll need to submit Form 433-A. This is a Collection Information Statement for Wage Earners and Self-Employed Individuals. It provides the IRS with a detailed picture of your income, expenses, assets, and liabilities. You may also need to submit documents such as pay stubs, bank statements, and bills to prove your financial hardship.
Other Tax Relief Options
You can also look into other forms of tax relief if your IRS levy is causing a hardship. An Offer in Compromise (OIC) is an agreement between you and the IRS that settles your tax debt for less than the full amount you owe. This option may be available if paying the full tax liability would cause financial hardship. To apply, you’ll need to submit Form 656 and provide detailed financial information. While this option can provide significant relief, it’s important to understand that the IRS approves only a small percentage of OIC applications. The process is rigorous, and you may want to consult a tax professional to increase your chances of success.
If a full release of the levy isn’t possible, you may be able to negotiate an installment agreement. This allows you to pay off your tax debt over time in smaller, more manageable payments. While the IRS may not release the levy entirely, they may adjust it to a level that no longer creates a hardship.
Appeal the Levy
If you believe the levy was wrongfully applied or if you disagree with the IRS’s decision, you have the right to appeal. You can request a Collection Due Process (CDP) hearing, where you’ll have the opportunity to present your case. During this hearing, you can propose alternatives to the levy, such as an installment agreement or Offer in Compromise.
Seek Professional Help
Navigating the complexities of tax laws and IRS procedures can be challenging, especially when you’re under the pressure of a levy. Consider consulting a tax professional, such as a certified public accountant (CPA), enrolled agent, or a tax attorney, who can help you negotiate with the IRS and explore your options for relief.
Prepare for the Future
Once the immediate crisis is resolved, take steps to prevent future tax issues. Set up a payment plan with the IRS if you still owe back taxes and ensure that you stay current with all future tax obligations. Consider working with a tax professional to manage your finances and avoid falling into similar situations in the future.
Tax Help for Those Being Levied by the IRS
An IRS levy can be overwhelming, but it’s important to know that options are available, especially if it’s causing a financial hardship. By taking proactive steps, communicating with the IRS, and seeking professional help, you can work towards resolving the issue and regaining financial stability. Optima Tax Relief is the nation’s leading tax resolution firm with over $3 billion in resolved tax liabilities.
