Senior Tax Attorney at Leading Tax Group | IRS Collection Matters for Individuals and Businesses
Shadi Halavi Shaolian is a Senior Tax Attorney at Leading Tax Group with more than 15 years of experience handling IRS collection matters for individuals and businesses. Her experience includes working with taxpayers on Installment Agreements, Offers in Compromise, penalty abatement, and other IRS collection matters.
Her practice is particularly focused on helping taxpayers understand and respond to IRS collection problems. These matters can involve more than simply determining how much tax is owed. The IRS may examine a taxpayer’s income, expenses, assets, liabilities, and ability to pay when evaluating certain collection alternatives. Shadi’s experience in this area allows her to help clients understand the collection process and evaluate potential resolution options based on their individual financial circumstances.
Shadi earned her Juris Doctorate from Loyola Law School in 2008 after completing her Bachelor of Arts in English at the University of California, Berkeley in 2003. She was admitted to the State Bar of California in June 2010.
She is also a member of the Los Angeles County Bar Association, American Bar Association, and American Society of Tax Problem Solvers (ASTPS).
Areas of IRS Experience
Shadi has more than 15 years of experience with IRS collection matters, with a particular focus on individual and business IRS collections.
Her experience includes matters involving:
- IRS Installment Agreements
- Offers in Compromise
- Penalty abatement
- Individual IRS collection matters
- Business IRS collection matters
- IRS financial analysis
- Collection-related financial statements
- IRS levy matters
- Tax resolution options
A central part of resolving many IRS collection matters is understanding the taxpayer’s financial position rather than approaching every case with the same resolution strategy.
Experience With IRS Installment Agreements
An IRS Installment Agreement may allow an eligible taxpayer to resolve an outstanding federal tax liability through payments over time rather than paying the entire balance immediately.
Shadi’s IRS collection experience includes working with installment agreements for taxpayers who need an alternative to immediate full payment.
The appropriate payment arrangement can depend on the taxpayer’s circumstances, including income, necessary expenses, assets, outstanding liabilities, and the amount owed to the IRS. This is why an IRS collection case should generally be evaluated based on the taxpayer’s actual financial information rather than assumptions about what the IRS may accept.
Experience With Offers in Compromise
Shadi also has experience handling Offers in Compromise (OIC).
An Offer in Compromise is an IRS program through which qualifying taxpayers may be able to resolve a federal tax liability for less than the full amount owed. It is not, however, an automatic tax-debt reduction program.
One misconception Shadi has encountered among taxpayers is the belief that the IRS will reduce a tax liability simply because the taxpayer is experiencing difficult personal or financial circumstances.
In practice, potential agreements with the IRS can require an in-depth analysis of the taxpayer’s income, expenses, and assets to determine what resolution may be available and what the IRS may accept.
This financial analysis can be particularly important when determining whether a taxpayer may qualify for an Offer in Compromise or another collection alternative.
Experience With IRS Penalty Abatement
Shadi’s IRS collection experience also includes penalty abatement matters.
IRS penalties can significantly increase an outstanding tax balance. Depending on the circumstances and applicable IRS requirements, a taxpayer may have grounds to request that certain penalties be reduced or removed.
Whether penalty relief may be available depends on the facts of the taxpayer’s situation and the applicable IRS rules. For this reason, penalty abatement should be evaluated based on the taxpayer’s actual circumstances rather than assuming that penalties will automatically be removed.
Understanding IRS Financial Statements: Forms 433-A and 433-F
An important part of Shadi’s experience involves the financial information taxpayers may need to provide when attempting to resolve an IRS collection matter.
Two forms that taxpayers may encounter are:
- IRS Form 433-A – Collection Information Statement for Wage Earners and Self-Employed Individuals
- IRS Form 433-F – Collection Information Statement
Based on Shadi’s experience with individuals preparing these financial statements, one recurring issue is the use of rounded or estimated amounts instead of specific figures.
The financial information supplied to the IRS can be important when the agency evaluates a taxpayer’s ability to pay and potential collection resolution.
For taxpayers, this means preparing an IRS financial statement should not be treated as simply filling in approximate monthly expenses. Accurate documentation and careful financial analysis can play an important role in the collection process.
How Does the IRS Evaluate a Taxpayer’s Ability to Pay?
A common misconception among taxpayers is that an IRS collection resolution is based primarily on explaining why paying the tax would be personally difficult.
According to Shadi’s experience handling IRS collection matters, the process generally requires a much more detailed financial analysis.
Depending on the collection option involved, relevant financial information can include:
- Income
- Living and business expenses
- Assets
- Liabilities
- Available equity
- Ability to make payments
This information can help determine what collection alternatives may be available and what type of arrangement the IRS may consider.
For this reason, two taxpayers who owe similar amounts may not necessarily receive the same collection resolution. Their underlying financial circumstances can be substantially different.
Can the IRS Take a Taxpayer’s House or Car?
One of the most common questions Shadi receives from taxpayers facing IRS collection problems is:
“Can the IRS take my house or car?”
The answer requires more context than a simple yes or no.
The IRS has legal collection powers when federal tax liabilities remain unresolved and applicable procedural requirements have been satisfied. However, that does not mean every taxpayer who owes the IRS will automatically have a house, vehicle, or other property seized.
Based on Shadi’s experience, the analysis can involve factors such as:
- The value of the property
- Loans or other obligations against the property
- Available equity
- Quick-sale value
- The nature of the property
- Whether the property is important for producing income
Potential collection alternatives may also be relevant depending on the taxpayer’s circumstances, including payment arrangements or an Offer in Compromise.
Therefore, receiving an IRS collection notice should not automatically be interpreted as confirmation that a particular asset will be seized.
IRS Notices That Should Receive Prompt Attention
Through her IRS collection work, Shadi identifies notices involving an Intent to Levy or Final Notice of Intent to Levy as correspondence that taxpayers should address promptly.
Common IRS notices encountered in collection and tax matters include:
- IRS CP504
- IRS CP2000
- IRS Letter 1058 / Final Notice of Intent to Levy
- Annual IRS notices
Different IRS notices have different purposes, deadlines, and procedural implications. Taxpayers should therefore review the exact notice received rather than assuming that all IRS collection correspondence means the same thing.
Representative IRS Collection Experience
Shadi’s experience includes IRS collection matters in which taxpayers faced significant financial and business consequences.
In one matter shared by Shadi, a taxpayer’s business depended on income received through Medicare and Medicaid-related payments. IRS collection activity involving federal payments reportedly caused the taxpayer’s business income to be held toward outstanding tax balances, placing business operations at risk.
Shadi worked with IRS personnel regarding the federal payment levy and reports that she was able to obtain a release of the levy so that the taxpayer could continue operating the business while a longer-term resolution was developed.
This example illustrates an important aspect of IRS collection work: the immediate collection problem and the long-term tax resolution may need to be addressed separately.
Representative matters are provided for informational purposes only. Past results do not guarantee or predict outcomes in other cases.
Experience With Audit Reconsideration
Shadi has also provided an example involving a taxpayer whose deductions had been disallowed during an IRS audit.
The taxpayer reportedly faced approximately $35,013 plus interest and penalties after the IRS rejected documentation supporting the deductions.
An audit reconsideration was requested. According to Shadi, detailed analysis of the taxpayer’s bank and credit-card statements was used to address the IRS’s concerns regarding the claimed losses.
The reported outcome was a reduction of the assessed balance to zero, followed by an approximately $40,000 refund after the relevant statute-related issue was addressed.
The case demonstrates why supporting financial records and detailed analysis can matter when disputing an IRS audit determination.
Every tax matter depends on its individual facts and applicable law. Past outcomes do not guarantee similar results.
Education
Loyola Law School
Juris Doctorate, 2008
University of California, Berkeley
Bachelor of Arts in English, May 2003
Bar and Court Admissions
- State Bar of California — June 2010
- District Court of California — 2010
- Tax Court of California — 2011*
The exact court title should be confirmed before publication.
Professional Memberships
Shadi’s professional memberships include:
- Los Angeles County Bar Association
- American Bar Association
- American Society of Tax Problem Solvers (ASTPS)
Media & Interviews
Voyage LA has interviewed Shadi.
Frequently Asked Questions About Shadi Halavi Shaolian
1. What type of tax matters does Shadi Halavi Shaolian handle?
Shadi focuses on individual and business IRS collection matters. Her experience includes Installment Agreements, Offers in Compromise, penalty abatement, financial analysis, and other collection-related issues.
2. How much IRS collection experience does Shadi have?
Shadi has more than 15 years of experience working with IRS collection matters.
3. Does Shadi handle IRS Installment Agreements?
Yes. Installment Agreements are among the IRS collection matters included in her experience.
4. Does Shadi handle Offers in Compromise?
Yes. Her experience includes Offers in Compromise and evaluating taxpayer financial circumstances relevant to IRS collection resolutions.
5. Does Shadi work with businesses that owe the IRS?
Yes. Her stated area of specialization includes both individual and business IRS collections.
6. Does Shadi have experience with IRS financial statements?
Yes. Her experience includes issues involving IRS Forms 433-A and 433-F and the financial information used in evaluating collection matters.
7. What does Shadi identify as a common IRS tax-resolution misconception?
One misconception she frequently encounters is the belief that personal financial struggles alone will automatically cause the IRS to reduce a tax liability or accept a lower payment. IRS collection resolutions can instead require detailed analysis of income, expenses, assets, and the taxpayer’s overall financial circumstances.
8. Which IRS notices does Shadi believe require prompt attention?
Based on the information she provided, taxpayers should pay particular attention to an Intent to Levy and a Final Notice of Intent to Levy, because these notices can indicate that the IRS collection process has reached an important stage.
About Shadi Halavi Shaolian
Shadi Halavi Shaolian is a Senior Tax Attorney at Leading Tax Group with more than 15 years of experience handling IRS collection matters for individuals and businesses. Her experience includes IRS Installment Agreements, Offers in Compromise, penalty abatement, financial statements, levy matters, and other collection-resolution issues.
Her approach to IRS collection matters emphasizes understanding the taxpayer’s complete financial circumstances and evaluating available options based on the facts of the individual case.
800-900-4250
