Tennessee Department of Revenue (TDOR) Tax Attorney in Knoxville, TN

Navigating tax issues with the Tennessee Department of Revenue (TDOR) can be a challenging and stressful experience. While the TDOR may not be as well-known as the Internal Revenue Service (IRS), it has equally powerful enforcement tools and can act swiftly, particularly against businesses. A state tax lien or levy can impair operations just as much as a federal one. Whether you’re facing a sales tax audit, a delinquent tax bill, or other enforcement action, it’s crucial to have experienced legal counsel.
At Easter & DeVore, our Knoxville-based team helps individuals and businesses resolve a wide range of state tax issues involving the TDOR. We strive to protect your rights, minimize your liability, and reach a workable resolution through strategic advocacy based on Tennessee tax laws.
Understanding TDOR Tax Issues
The Tennessee Department of Revenue is responsible for administering and collecting various state taxes, including:
- Sales and use tax – the primary revenue source, with complex rules for taxable services, exemptions, and nexus.
- Franchise and excise tax – the state’s primary business taxes, based on net worth and net earnings.
- Business tax – a tax on gross receipts for the privilege of doing business in a municipality or county.
- Hall income tax (for prior years) – though repealed for tax years beginning on or after January 1, 2021, liabilities for prior years remain enforceable.
- Alcohol, tobacco, and motor fuel taxes – highly regulated excise taxes with strict reporting.
- Individual income and withholding tax issues – including employer withholding compliance and individual residency audits.
Understanding the nuances of each tax law is crucial. For example, Tennessee’s sales tax regulations for services are especially complex, and errors in determining nexus (when a business outside of Tennessee becomes responsible for paying Tennessee taxes) can lead to frequent audits. If the Tennessee Department of Revenue (TDOR) believes you have underpaid taxes or failed to file a required return, they may send you a notice of assessment or take enforcement action. Our attorney can help you review your tax situation, evaluate the notices, and develop a strategy to address the issue and prevent the escalation of penalties effectively.
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TDOR Audits and Assessments
Being audited by the Tax Division of Revenue (TDOR) can disrupt your business or personal finances. These audits may be triggered by reporting inconsistencies, unusual deductions, random selection, or industry-wide compliance initiatives. Unlike the Internal Revenue Service (IRS), TDOR auditors often focus on a single type of tax, such as sales tax. They can be extremely detail-oriented when reviewing exemption certificates, purchase invoices, and tax accruals.
We represent clients during TDOR audits by:
- Communicating with state auditors on your behalf from the very first contact, ensuring a professional and controlled interaction.
- Gathering and organizing records for review in a manner that is responsive yet designed to limit unnecessary expansion of the audit scope.
- Challenging inaccurate findings and unjust assessments by interpreting Tennessee statutes, regulations, and case law to support your position.
- Negotiating settlements or payment plans that fairly reflect the actual liability, often through a formal written protest and negotiation process.
Our goal is to reduce your exposure and resolve the audit with minimal disruption to your business or daily life.
Sales and Use Tax Issues
Sales and use tax compliance is a common and significant challenge for businesses in Tennessee. Errors in collecting, reporting, paying, or understanding what is taxable (such as software, delivery fees, and bundled transactions) can lead to costly penalties and interest charges. The Tennessee Department of Revenue (TDOR) aggressively pursues sales tax audits, which can result in assessments that span multiple years and create a sudden and overwhelming debt burden.
We help businesses resolve sales tax issues by:
- Reviewing tax Reviewing tax records and sales documentation to identify the root cause of any discrepancy. and sales documentation
- Identifying errors and misclassifications in taxability determinations and applying the correct Tennessee law.
- Negotiating settlements or payment arrangements that may include penalty abatement requests based on reasonable cause.
- Applying for voluntary disclosure agreements (VDAs), where applicable. This is a powerful and proactive tool for businesses that may have unknowingly created a Tennessee nexus, but have not yet been contacted by the Tennessee Department of Revenue (TDOR). A properly filed VDA can help limit the look-back period and may waive all penalties associated with the issue.
Resolving Delinquent Tax Debt
If you owe back taxes to the TDOR, you may face swift collection actions such as wage garnishment, bank levies, or tax liens. The TDOR Collection Division can be aggressive, and their liens are attached instantly upon recording. However, like the IRS, they also have formal resolution processes. Our attorney works with the TDOR to:
- Negotiate installment payment plans tailored to your cash flow, preventing further enforcement.
- Request penalty relief or abatement by demonstrating reasonable cause, such as reliance on a professional advisor or circumstances beyond your control.
- Assist with offers in compromise, when available. While less common than with the IRS, TDOR does have a compromise program for cases where collection is doubtful or where payment would create an economic hardship.
- Protect your property and financial accounts from enforcement actions by filing the necessary appeals or securing a hold on collections while a resolution is negotiated.
Each case is handled with a personalized approach, taking into account your financial situation and long-term goals. We prioritize securing a “Collection Hold”, which stops active garnishments or levies, while we work towards a permanent solution.
Why Local Expertise in Tennessee Tax Law is Critical
The tax code in Tennessee and the administrative procedures of the Tennessee Department of Revenue (TDOR) have their own specific characteristics. Successfully navigating through a state tax dispute requires a deep understanding of Tennessee’s laws, the practices of the local audit division, and the negotiation routes within the Department of Revenue in Nashville. Our lawyers bring this specialized knowledge, ensuring that your case is handled with the insight that a general practitioner or national firm may not have.
Contact Easter & DeVore
If you are dealing with a tax issue involving the Tennessee Department of Revenue (TDOR), we at Easter & DeVore in Knoxville, TN, can help. We have experience handling audits, assessments, and collections, and we are dedicated to finding a practical and lasting solution for your tax issues.
Do not ignore a TDOR notice. It is important to involve a lawyer early to control the process, limit your liability, and protect your assets. Schedule a consultation with us today to discuss your situation and take the first step towards resolving your state tax problems with confidence.
Common Department of Revenue FAQ
TDOR administers most state taxes, including Sales & Use Tax, Franchise & Excise Tax, Business Tax, and alcohol/tobacco taxes. It also handles individual income tax withholding issues and past-due Hall Income Tax. Our practice covers the full spectrum of TDOR disputes.
Act quickly. You have a limited time to protest the assessment before it becomes final. Contact us immediately to review the notice, identify the underlying issue, and file a formal protest to protect your right to appeal and negotiate a resolution.
Auditors will examine your sales records, exemptions, and tax returns, often for a multi-year period. They assess additional tax, penalty, and interest if they find underpayments. We manage the entire process, communicate with auditors to limit the scope, and challenge unsupported findings to reduce your liability.
Yes. The Voluntary Disclosure Agreement (VDA) program may allow you to come forward voluntarily, pay back taxes for a limited “look-back” period, and avoid penalties. We can confidentially negotiate a VDA with TDOR to bring your business into compliance affordably.
TDOR can file a tax lien against your property, garnish wages and bank accounts (levy), suspend business licenses, and even pursue personal liability against responsible individuals. We intervene to stop these actions by entering into formal resolution negotiations.
Yes. TDOR often negotiates Installment Agreements for paying debt over time. In some cases, they may accept an Offer in Compromise to settle for less than the full amount owed, though criteria are strict. We assess your situation to pursue the most favorable resolution option.
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