top of page


To Register as a Client or Request a Proposal
A proactive approach allocates legal resources to improve processes and procedures that cultivate profitability and foster strategic growth, through automation, standardization and transaction structure. 

Many small businesses fail to investigate the proper application of sales, use, excise, payroll, personal property, business license and other state and local taxes to their particular type of business. After years of operating without tax compliance, companies can find themselves owing several times the amount of the original tax liability as a result of interest and penalties. In addition, sales tax and payroll tax fall within the family of trust fund taxes for which owners may have personal liability without regard to the protections offered by the corporate veil to owners of corporations or limited liability companies. Moreover, these liabilities may not be discharged in a personal bankruptcy and can therefore follow owners for decades. Likewise, federal tax planning impacts the taxes that a business will pay. The difference can be dramatic, especially in a transactional setting.


There are few areas of the law as complicated as corporate or partnership taxation. Poor tax planning or adverse IRS actions can severely impact a small or medium-sized business. If you are concerned you haven’t been getting reliable advice on taxation, or you have an audit upcoming, Spizzirri Law is prepared to help. We handle all tax law matters, including tax law opinions, tax preparation and filing review, IRS and state tax audits, collection defensive measures, and criminal tax defense. Our reputation for integrity and professionalism helps us work effectively even under the most adverse circumstances to resolve tax problems favorably for our clients.

We provide the proactive representation you need to prepare your company for the audit, including sound and effective tax law opinion letters, tax books and records documentation, and maintenance and tactical initiatives to support your company’s tax strategies. We serve as your legal representative throughout the audit, defending your tax practices whenever the auditors raise an issue. When errors are uncovered, we can often negotiate a settlement that satisfies tax investigators and avoids an escalation of the controversy.


Our experienced staff includes revenue officers and auditors who spent decades working at the Internal Revenue Service. We apply a multi-faceted approach that includes verifying that the tax, penalties, and interest claimed due have been correctly calculated. We then complete a financial analysis of each taxpayer’s specific facts and circumstances to determine the amount each tax pair can pay. Finally, we negotiate appropriate payment arrangements with the Internal Revenue Service including installment plans, an offer in compromise, or a Payment deferral.

The IRS has aggressive tools at its disposal to collect back taxes and penalties. However, indiscriminate use of such tools, including the filing of tax liens can restrict your access to the capital. Suddenly you are faced with a Catch 22: use capital to continue operations, so it’s impossible to repay what you owe, or repay your back taxes, but cease business operations.

This choice can be even more difficult when tax compliance failures come as a surprise result of an audit examination where previously unknown liabilities for tax, interest, and penalties can exceed your ability to pay. Before you let IRS collections force you into bankruptcy, consult a knowledgeable tax attorney who can protect your rights.


If you went to a doctor with a complaint about chest pains, and he told you not to worry because it’s only indigestion, you might want a second opinion. After all, if he’s wrong, you’ve got a great deal to lose, especially if you plan to run a 5K next week. The same logic applies to taxation. If your company is mulling over a development strategy, you need to know if your taxation plan can survive scrutiny from the Internal Revenue Service, or if an alternative tax structure could reduce your exposure further without raising red flags. At Spizzirri Law, tax opinion letters constitute a significant part of our business law practice. Client businesses rely on our analysis when making strategic decisions that depend on favorable tax consequences.

A mistaken assumption in your company’s tax strategy can destroy the value of a complex transaction. Before you move forward on your development strategy or engage in a tax dispute with the IRS, let Spizzirri Law provide an unbiased opinion of your tax issues.

We thoroughly examine the details of a proposed transaction, scrutinize the tax plan, and draft a detailed opinion letter, affirming or denying the legal and factual bases for the tax assumptions in the plan. When our letter declares why we, as a disinterested party, believe the corporation’s proposed tax strategy is meretricious, this result sets shareholder minds at ease, and insulates board members from potential allegations they breached their fiduciary duty in approving the transaction. The company can structure the transaction with confidence and will generally find it much easier to raise capital and at a lower cost. Our clients can often secure prior IRS approval that removes any shadow of controversy from the transaction.

On the other hand, when our tax opinion raises red flags about potential conflicts with the U.S. Tax Code, your company now has actionable intelligence to help you rework the deal on a sounder basis.

We help find a passage.
bottom of page