Services
One focus: resolving IRS tax debt.
I don't do a little bit of everything. My practice is IRS collections — getting people out from under tax debt through the programs Congress and the IRS actually provide. Here's each one, what it takes, and what it costs.
Installment Agreements
A monthly payment the IRS accepts — and you can actually live with.
An installment agreement is the workhorse of tax resolution: a formal monthly payment plan that stops enforced collection. The catch is the amount. Left to its own defaults, the IRS will push for a payment based on its formulas, not your life.
My job is the negotiation. I document your income and allowable expenses under the IRS's own standards, push for the lowest supportable payment, and structure the agreement so a missed nuance doesn't default it six months in. Where the facts support it, I pursue partial-pay agreements that resolve the debt for less than the full balance over the collection statute.
Self-employed taxpayers carry a heavier lift — business income analysis, quarterly estimated-tax compliance, and closer IRS scrutiny — which is why that tier is priced separately.
Offer in Compromise
Settle the debt for less than you owe — when the math is on your side.
An Offer in Compromise lets qualifying taxpayers settle their full tax debt for less than the balance — sometimes dramatically less. It's also the most oversold product in this industry. National firms pitch "pennies on the dollar" to people who will never qualify, collect the fee, and let the offer die.
I run the numbers first. An OIC turns on one figure: your reasonable collection potential — what the IRS believes it could collect from your equity and future income. I compute it before you engage me for an offer. If your RCP is near or above your balance, I'll tell you an offer is the wrong tool and point you to the right one. That conversation is free.
When the numbers work, I build the complete package — Form 656, the 433-A (OIC) financial statement, and the documentation that survives an offer examiner's review — then defend it through processing. Business income adds real complexity, which the Schedule C and S-Corp tiers reflect.
Currently Not Collectible
When you truly can't pay, the law lets the IRS stand down.
If paying the IRS anything would leave you unable to cover basic living expenses, you may qualify for Currently Not Collectible — hardship — status. The IRS marks your account, and enforced collection stops: no levies, no garnishments, no payment demands.
CNC is more strategic than it looks. The ten-year collection statute keeps running while you're in hardship status. For taxpayers near the end of that clock, CNC isn't just breathing room — it can be the path to the debt expiring entirely. I document the hardship the way the IRS requires, place the account, and monitor it so a routine income review doesn't quietly knock you back into collections.
Offer in Compromise Appeals
A rejected offer gets a second, independent look. Take it.
Offer examiners get it wrong — they overvalue assets, disallow legitimate expenses, or project income that isn't real. When that happens you have 30 days to request an appeal, and IRS Appeals is a genuinely independent forum with settlement authority the examiner never had.
I take rejected offers to Appeals and argue the valuation. Whether I filed your original offer or you filed it yourself (or through one of those national firms), I identify where the examiner's math went wrong and make the case to the settlement officer. Deadline-critical work — if you've received a rejection letter, the clock is already running.
Innocent Spouse Relief
Their tax debt shouldn't have to be your tax debt.
A joint return makes both spouses fully liable for everything on it — including income a spouse hid, deductions they invented, or a balance they promised to pay and didn't. Divorce decrees don't change what you owe the IRS. Form 8857 relief can.
These cases are won on the story and the record. Innocent spouse, separation of liability, and equitable relief each have their own tests, and the IRS weighs factors like knowledge, benefit, abuse, and financial control. I build the factual record, choose the strongest theory, and pursue the claim — discreetly, and with the safeguards federal law provides for domestic-abuse situations.
Scam Victim Recovery
Scammed? If you can document it, the case is free. New Hampshire residents only
Two kinds of scam victims land in this office again and again. Individuals taken by digital currency scams — fake crypto "investment platforms" and romance-investment schemes that persuaded them to liquidate savings and retirement accounts, leaving them with nothing but a tax bill on the withdrawals. And retired individuals who paid national tax debt relief companies that advertised "pennies on the dollar," collected thousands in fees — often from cashed-out retirement funds — then closed their doors and went out of business having done little or no work.
If either happened to you, you are a New Hampshire resident, and you can document it, Attorney Clarke represents you at no charge. Bring proof of what you paid and what happened. The goal is to at least recover the taxes you paid on the retirement funds you withdrew — and, where a path exists, more — while getting any underlying tax debt onto a legitimate resolution track.
Delinquent Return Preparation
Unfiled returns are the locked door. This is the key.
The IRS will not accept an Offer in Compromise, an installment agreement, or hardship status from a taxpayer with unfiled returns — filing compliance is the price of admission to every resolution program. Yet unfiled years are exactly where many tax debt cases start.
So the practice prepares returns at flat, published rates — current-year or delinquent, individual or corporate (including 1120-S): $300 for a simple federal return, $100 for each additional state, $1,000 for self-employed taxpayers filing a Schedule C, and $1,200 where self-employment income runs through an S-Corp. Returns are prepared from transcripts and your records, filed in the sequence the IRS needs, and rolled straight into your resolution strategy.
Collection Appeals — Form 9423
Rejected plan? Levy? Lien? The CAP appeal moves fast.
When the IRS rejects or terminates an installment agreement, files a lien, or moves to levy wages or accounts, you're not stuck with the collection employee's decision. The Collection Appeals Program (Form 9423) puts the action in front of a manager and then an independent Appeals officer — and it's the fastest appeal route the IRS offers, often resolving before enforcement lands.
Speed is the whole game in a CAP case. The windows are short and strict. Attorney Clarke files the appeal, makes the case to Appeals, and works the underlying problem — usually repairing or replacing the payment arrangement — so the levy or lien threat doesn't come straight back.
Offshore & FBAR Compliance
Foreign accounts, unfiled FBARs — fixed before they become penalties.
If you've held foreign financial accounts and never filed FBARs — or never reported the income — the penalty exposure can dwarf the tax itself. The IRS provides structured ways back into compliance: delinquent FBAR submission procedures, the Streamlined Filing Compliance Procedures for non-willful cases (Forms 14653/14654), and the Voluntary Disclosure Practice, the successor to the old Offshore Voluntary Disclosure Program, for cases with willfulness exposure.
Choosing the right door matters enormously — the wrong program can mean unnecessary penalties or, worse, an admission in the wrong forum. Attorney Clarke assesses willfulness risk, selects the route, prepares the filings and the certification narrative, and manages the disclosure through acceptance — for a flat $5,000, published like every other fee here.
Everything Else
Clear scope first. Then a flat fee, same as everything above.
Tax debt cases sprawl: lien withdrawals and subordinations, levy releases, penalty abatement, unfiled-return strategy, payroll tax and trust-fund penalty defense, audits that feed into collections. Some of these can't be honestly flat-priced before I've seen your transcripts.
So the structure is simple. Work outside the core services runs at $300 per hour only until the scope is clearly defined — then I convert the engagement to an agreed flat fee, in writing, and that's the number. You get flat-fee certainty without me padding a quote to cover unknowns.
Start with a free 30-minute scheduled phone consultation,
followed by a 30-minute free video or Portsmouth, NH office consultation.
For your convenience, Attorney Clarke is willing to travel to a Regus satellite office in Nashua, Bedford, Manchester, and Concord, NH, or to a Regus office in Boston, Bedford, Peabody, Wakefield and Lawrence, MA, to discuss your case in person.
If you live outside NH and MA, Attorney Clarke can still represent you before the IRS under federal practice rules. In this case, all meetings can be held through phone or video conferencing.
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