Building an IRS Tax Collection Representation Practice – The Tax Procedures You Need to Know

Eli Noff, JD, CPA is a skilled tax attorney and CPA, who focuses his practice on defending clients before the IRS and state taxing authorities. With extensive experience in international tax matters, Eli focuses on issues including compliance, voluntary disclosures, streamlined filing procedures, and penalty abatements. His practice spans a wide array of services, from assisting clients with IRS examinations and appeals to handling international tax consulting, tax debt resolution, and matters before the United States Tax Court.

Throughout his career, Eli has helped clients manage complex tax debt situations, utilizing solutions such as offers in compromise, installment agreements, and collection alternatives. His goal is to provide personalized solutions based on each client’s unique circumstances, using his deep understanding of tax law to secure the best possible outcomes.

Eli serves clients in Maryland, the District of Columbia, and federal tax clients nationwide.

Practice Areas

Tax Law, Tax Controversy, International Tax Consulting

Speaking Engagements & Panel Participation

Eli has presented on various tax topics, including IRS collections, international tax compliance, and managing significant tax debts. He has also appeared on The Goldstein on Gelt Show to discuss the importance of FBAR reporting.

Publications

Eli has authored numerous articles on topics such as foreign trust reporting, IRS enforcement priorities, FBAR compliance, and international tax strategies. His publications offer valuable insights for professionals and taxpayers navigating the complexities of tax law.

Professional Associations

• American Bar Association
• Maryland State Bar Association
• American Bar Association Section of Taxation
• Past Chair, American Bar Association Committee on Tax Collection, Bankruptcy, and Workouts
• Maryland Volunteer Legal Services Mentorship Program
• Fellow of the American Bar Foundation

Education

• University of Maryland School of Law, Juris Doctorate, cum laude
  Baltimore, MD
• Ner Israel Rabbinical College, Bachelor of Talmudic Law
  Pikesville, MD
• The University of Memphis
  Memphis, TN

Speaking Engagements / Classes / Seminars

• Maryland Society of Accounting and Tax Professionals (MSATP)
• Maryland Association of Certified Public Accountants (MACPA)
• Maryland State Bar Association (MSBA)
• National Association of Tax Professionals (NATP)
• American Bar Association (ABA)

Honors / Distinctions / Awards

• Super Lawyers Rising Stars (2015–2023)
• Top Lawyers of Maryland (2020)
• Leading Lawyers (2022-2023)
• Best Lawyers Ones To Watch (2023-2024)
• Super Lawyers (2024)
• Best Lawyers (2025)

Previous Professional Experience

• Partner – Frost & Associates, August 2012 – November 2024

Justin Hughes, JD, CPA, LLM resolves tax issues for individuals and businesses. He has extensive experience as a CPA and also as a tax attorney. His experience allows him to efficiently and effectively assist clients in a variety of settings, including federal and state examinations, appeals, Tax Court, and all aspects of tax collections.

Over his career, he has helped individuals and businesses reduce their proposed income tax adjustments by millions of dollars in IRS examinations, Appeals, and Tax Court. He has helped a number of taxpayers reduce or eliminate their existing tax debts through offers in compromise and other post-assessment procedures. In addition, he has helped taxpayers with significant tax debts enter into collection alternatives.

His goal is always first to understand a client’s situation and then determine the best solution for the client based upon their specific facts and circumstances. He always seeks to find an efficient way to help his clients minimize their current tax burden and manage their future tax risk.

Justin serves clients in Maryland and federal tax clients worldwide.

Practice Areas

Tax, Tax Controversy, Tax Planning

Professional Associations

• American Bar Association
• Maryland Bar Association
• Pennsylvania Bar Association
• New York Bar Association
• Certified Public Accountant - Maryland
• Certified Public Accountant - Pennsylvania

Education

• New York University School of Law, LL.M. in Taxation
  New York, NY - 2007
• Case Western Reserve University School of Law, Juris Doctorate
  Cleveland, OH - 2006
• Pennsylvania State University, Bachelor of Arts in Accounting
  University Park, PA - 1999

Representative Experience*

*Please note that each case is different and my past record is no assurance that I will be successful in reaching a favorable result in any future case.

• IRS CP2000 – Reduced proposed IRS adjustment based upon incomplete brokerage data on Forms 1099.
• IRS CP2000 – Eliminated proposed IRS adjustment based upon gross activity from cryptocurrency exchange reported to IRS on Form 1099-K.
• IRS Civil Examination – Assisted small Schedule C business receive a no-change letter from IRS after compliance research examination.
• IRS Civil Examination – After receipt of the draft examination report, assisted real estate broker to reduce the IRS’s proposed adjustments by more than $250,000
• IRS Civil Examination – After receipt of draft report, assisted client in Amazon retail business reduce proposed tax, penalties, and interest by approximately $800,000.
• IRS Civil Examination – Reached civil settlement in several eggshell examinations involving unreported income in excess of six figures.
• IRS Appeals – Successfully appealed Revenue Agent’s denial of real estate professional status.
• IRS Appeals – Successfully appealed proposed penalty for late filing of Form 3520.
• U.S. Tax Court – Obtained six figure reduction in proposed tax and penalties by challenging tax computations and lack of managerial penalty approval.
• IRS Offer in Compromise – Successfully reduced business owner’s tax debts (both individual income tax and TFRP) through Offer in Compromise.
• IRS Offer in Compromise – Successfully reduced business’s federal tax debt by seven figures through Offer in Compromise.
• IRS Appeals -Trust Fund Recovery Penalty – Successfully challenged assertion of TFRP against adult children for family businesses’ unpaid payroll tax.
• Federal Worker Classification Examination – After draft report was received, Utilized Fast Track Settlement program to reach favorable resolution based upon IRS’s Classification Settlement Program (CSP).
• Federal Information Return Penalties – Assisted client in successfully challenging proposed penalties on IRS Form 972CG regarding taxpayer identification number matching errors on Forms 1099-MISC.
• Maryland Personal Assessment – Successfully appealed Maryland Comptroller’s proposed personal assessment against executor & beneficiary of estate for decedent’s business’s tax debts.
• IRS Private Letter Ruling – Obtained ruling that amounts reported to taxpayer on Form 1099-C by employer’s pension plan were not includable in income due to prior inclusion of income.
• IRS Private Letter Ruling – Obtained ruling granting waiver of 60-day rollover period for failed attempt to structure rollover and acquisition of real estate through self-directed IRA.
• IRS Levy Relief – Received partial refund of levy from account receivable due to IRS’s failure to allow necessary expenses, which caused an economic hardship.
• U.S. Tax Court – Reached favorable settlement with IRS counsel on partial deduction of of start-up expenses in excess of six figures.

Previous Professional Experience

• Owner – Law Office of Justin Hughes, LLC – 2014-2024
• Of Counsel – Frost Law – Annapolis, MD – 2014 – 2024
• Senior Manager – Deloitte Tax, LLP – M&A Transaction Services – New York, NY – 2008 to 2013
• Accountant – Fiore, Fedeli & Sndyer, P.C. – State College, PA – 1999 – 2003