IRS Releases Levies Of Prominent Oklahoma City Lawyer
The IRS has released a wrongful levy of a high profile OKC lawyer, who is our client. The Revenue Officer assigned to the case performed "research" of public court filings on the Oklahoma Supreme Court Network ("OSCN") and determined some of the lawyer's corporate clients from court filings. Also available to the R.O. in her search of these public filings were the courthouses in which lawyer practiced.
The R.O. then sent levies to 22 potential clients of lawyer to attempt to obtain monies that these clients might owe the lawyer, as attorney's fees. The IRS may levy third parties who hold money on behalf of a delinquent taxpayer. The problem here was, these clients had a contractual relationship with the corporate law office of the lawyer, not the lawyer individually. The lawyer individually owes the tax, not his law office. The IRS knows better, or it should.
To add insult to injury, the R.O. sent levies to the courthouses in which lawyer routinely practiced. Imagine my client's awe and surprise when a Court of Appeals Justice handed him a levy. I remain puzzled as to the theory whereby a court might be holding funds for an individual lawyer. Needless to say, relations between the lawyer and his clients and the courts he practices in have become strained. Of course, the R.O.'s response was essentially no-harm, no-foul, your client owes alot of taxes.