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The Kovel Accountant

Posted by Brandon Keim | Sep 18, 2026 | 0 Comments

For taxpayers facing criminal tax charges, a Kovel Accountant can be an important part of their defense strategy. Unlike traditional communications between a taxpayer and their attorney, these communications are protected. In other words, the IRS cannot access them.

The Trust Fund Recovery Penalty Interview

Posted by Brandon Keim | Sep 11, 2026 | 0 Comments

When a business fails to pay payroll taxes, the IRS may hold certain individuals personally liable for the unpaid taxes. Known as the Trust Fund Recovery Penalty (TFRP), this penalty covers unpaid income and employment taxes, such as Social Security taxes.

Structuring vs. Cash Hoarding

Posted by Brandon Keim | Aug 28, 2026 | 0 Comments

Structuring and cash hoarding are actions that can appear similar but have drastically different implications. For taxpayers, the similar appearance can potentially trigger issues with the IRS.

S Corporation Officer Compensation Audits

Posted by Brandon Keim | Jul 31, 2026 | 0 Comments

Qualifying as an S Corporation has significant advantages for shareholders. One of the biggest is avoiding double taxation on corporate income. These corporations pass all income, losses, deductions, and credits to their shareholders for federal tax purposes.

What are Jeopardy Assessments and Levies?

Posted by Brandon Keim | Apr 03, 2026 | 0 Comments

When the IRS wants to collect a tax debt, it has several options, including tax liens and levying property to satisfy a debt. But when the government is concerned that following the usual collection procedures will result in a loss to the government, they can use a jeopardy assessment or levy.

Subtleties of IRC Code Section 6321

Posted by Brandon Keim | Mar 30, 2026 | 0 Comments

Section 6321 of the Internal Revenue Code (IRC) grants the Internal Revenue Service (IRS) the ability to issue liens on a taxpayer's property. Overall, this provision is very broad, covering almost any delinquent taxes, but there are subtleties in the law that can profoundly impact taxpayers' liability.

Reclaiming Property Seized in an IRS Levy

Posted by Brandon Keim | Mar 27, 2026 | 0 Comments

If the IRS has levied and seized your property, you probably have many questions about how this works and whether you can recover your property. In some cases, you can recover your property if you act quickly enough, make alternate payment arrangements, or you can show the property seizure creates an economic hardship.

Is It Tax Fraud or Tax Evasion?

Posted by Brandon Keim | Mar 23, 2026 | 0 Comments

From news articles to casual conversations, people often use the terms “tax fraud” and “tax evasion” as if these two things are the same. But, in the eyes of the law, these concepts are not synonyms. They're different concepts with distinct requirements and consequences. Tax Fraud vs. Tax Evasio...

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The act of visiting or communicating with Brandon A. Keim via this website or by email does not constitute an attorney-client relationship. Communications from non-clients via this website are not subject to client confidentiality or attorney-client privilege. Further, the articles, discussion, commentary, forms and sample documentation contained in this website are offered as general guidance only and are not to be relied upon as specific legal advice. For legal advice on a specific matter, please consult with an attorney who is knowledgeable and experienced in that area. Attorneys listed in this website practice only in the jurisdictions in which they are admitted. This website is governed by the Arizona Rules of Professional Conduct.

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