We also have extensive experience representing clients before the Internal Revenue Service Collections Division.  In these cases, we frequently utilize one or more defensive measures, including offers in compromise, installment agreements, requests for innocent spouse relief, requests for collection due process hearings, collection appeal requests, and case submissions to the Internal Revenue Service, Office of Taxpayer Advocate Services.  Collection cases also present the opportunity for substantive tax planning as an option for resolving a case.  For example, many collection cases are a result of timing, including the mismatch of income in one year and expenses in a different year. Accordingly, collection cases are frequently multi-dimensional tax controversies.