Tax Attorney Serving Tennessee

Tax Law Attorney

An unresolved tax problem does not stay the same size — it grows every month through penalties and interest, and it can end in a lien on your property, a levy on your bank account, or a garnishment of your paycheck. At Devore Law PLLC, tax matters are handled exclusively by Devin S. DeVore, who represents clients before the Internal Revenue Service and the Tennessee Department of Revenue throughout the region.

Whether the issue is unfiled returns, a mounting balance you can’t pay, or an allegation that crosses into criminal exposure, Devin builds a resolution strategy around your actual financial picture and the specific agency you’re dealing with. His goal is to stop the collection actions and get you into a resolution that holds up.

Tax Law in Tennessee — What You Need to Know

Tax problems fall into two very different categories, and mixing them up leads to bad strategy. Civil tax debt — owing money you didn’t pay — is resolved through negotiation: payment plans, settlements, or hardship status. Criminal tax exposure — evasion or fraud — requires proving intent, and the government has to show you knew what you owed and deliberately tried to avoid it.

On the civil side, the IRS generally has 10 years from the date a tax is assessed to collect it — the Collection Statute Expiration Date (CSED). That clock sounds like relief, but it pauses any time you request an installment agreement, file an Offer in Compromise, or request a collection due process hearing, so it’s rarely as simple as waiting it out.

The Tennessee Department of Revenue runs a separate track entirely, with its own deadlines and collection procedures for sales tax, business tax, and franchise and excise tax. A client can be dealing with both agencies on different issues at the same time, and a strategy that works for one won’t necessarily satisfy the other.

Most tax problems are not fraud. An honest mistake, a bad year, or a return that never got filed doesn’t carry criminal exposure on its own — intent is what separates a civil balance from a criminal referral, and that distinction should shape how a case gets handled from the first conversation.

How Devore Law PLLC Can Help

A tax problem left alone doesn’t resolve itself — it escalates to liens, levies, and eventually criminal referral in the worst cases. Devin DeVore brings direct experience before both the IRS and the Tennessee Department of Revenue to every file.

IRS audit representation

Offer in Compromise negotiation

Installment agreement setup

Tax lien and levy release

Wage garnishment relief

Tennessee Department of Revenue disputes

Unfiled tax return resolution

Innocent spouse relief claims

U.S. Tax Court representation

Criminal tax defense for evasion and fraud allegations

Tax Debt Resolution Timeline in Tennessee

Tax resolution rarely moves fast, and clients benefit from knowing what to expect before they start.

The IRS has up to 10 years from assessment to collect — the Collection Statute Expiration Date — though this pauses during an active Offer in Compromise, installment agreement request, or appeal

An Offer in Compromise review commonly takes several months from submission to decision

Installment agreements can often be set up faster, though larger balances require more financial documentation upfront

Devin gives clients a realistic sense of which resolution path fits their timeline and financial picture, rather than defaulting to whichever option is easiest to file.

IRS and Tennessee Department of Revenue — Two Different Fights

Federal and state tax problems don’t run on the same rules, and treating them the same is a common mistake.

Internal Revenue Service (IRS)

Federal income tax debt, audits, and criminal tax exposure fall under the IRS, governed by the 10-year CSED and its own set of resolution programs, including the Offer in Compromise and Fresh Start policies.

TN Department of Revenue (TDOR)

Sales tax, business tax, and franchise and excise tax obligations run through the state, with separate collection timelines and its own settlement and payment plan procedures.

When Both Apply

Business owners in particular can face federal and state exposure on the same underlying facts at once, requiring a coordinated strategy so a concession to one agency doesn’t create a problem with the other.

Building the Resolution Case

Both the IRS and TDOR evaluate a resolution request based on a specific financial formula, not just what a client says they can afford. Reviewers weigh:

Reasonable collection potential based on income and asset equity

Allowable living expenses under IRS national and local standards

Compliance history, including whether all required returns have been filed

Current withholding or estimated payment status going forward

Common Areas of Focus

Reasonable Collection Potential

The IRS calculates what it believes it could realistically collect from your income and assets — this number, not your balance, usually sets the floor for a settlement offer.

Allowable Living Expenses

The IRS applies its own expense standards, which don’t always match actual spending, so documenting anything above those standards takes specific justification.

Asset Equity

Home equity, vehicle equity, and retirement accounts all factor into what a resolution requires you to contribute, even accounts you can’t easily access.

Compliance History

Missing returns or inconsistent estimated payments can disqualify an Offer in Compromise before the financial numbers are even considered.

I build each resolution request around the specific numbers that will actually move the reviewer, not a generic hardship narrative.

When the Stakes Are Criminal — Evasion and Fraud Allegations

Some tax matters cross a line the IRS and TDOR take seriously enough to refer for criminal investigation.

Tax Evasion

Tax evasion requires proof of a willful attempt to avoid a known tax obligation — concealing income, falsifying records, or structuring transactions to hide money. Owing tax you genuinely couldn’t pay is not evasion on its own.

Tax Fraud

Tax fraud centers on false statements made knowingly on a return or in dealings with the IRS or TDOR. A criminal referral changes everything about how a case should be handled, including what gets said to investigators before an attorney is involved.

What to Expect — The Tax Resolution Process

Case Review and Compliance Check

We review your notices, account transcripts, and filing history to confirm every required return is filed before pursuing any resolution option.

Two professionals in dress shirts and ties engaged in discussion over documents and a tablet at a meeting table.

Financial Disclosure and Documentation

We gather the income, expense, and asset documentation the IRS or TDOR requires, built around the standard they’ll actually apply.

Two professionals in business attire discussing documents and resumes at a wooden desk.

Negotiation with the IRS or TDOR

We submit and negotiate the resolution — an Offer in Compromise, installment agreement, or hardship status — based on what the numbers support.

Man in black suit holding brass balance scales on wooden desk.

Resolution and Compliance Monitoring

Once a resolution is in place, I make sure ongoing filing and payment requirements are met so the agreement doesn’t default.

Two individuals shaking hands over a wooden desk with legal documents and a gavel.

Why Work With Devin DeVore for Your Tax Matter

Tax representation at Devore Law PLLC is not delegated between attorneys. Devin DeVore personally handles every tax case, offering:

Direct access to your attorney

Experience before both the IRS and Tennessee Department of Revenue

Representation in state and federal court throughout East Tennessee

Active involvement in the Tennessee and Knoxville Bar Associations

Practical, numbers-first resolution strategy

His approach treats civil resolution and criminal exposure as genuinely different problems, and he builds the strategy around which one you’re actually facing.