The IRS Makes Substantial Changes to the Offer In Compromise Process

On May 21, 2012, the IRS announced a new expansion of its "Fresh Start" program.  As part of this expansion, IRS has made a number of substantial changes to the Offer In Compromise (OIC) program (the program that allows taxpayers to settle their debts with the IRS for less than they owe).  These changes are more defined than the original "Fresh Start" Streamlined OIC which promised flexibility for certain offers but did not provide specifics. 

These new changes revise the financial analysis used to qualify a taxpayer for the program.  As a result, more taxpayers will have a chance to participate in the program and those who have submitted an OIC in the past and were rejected should consider refiling.  

Key points of the changes include:

• Revisions made to the calculation of a taxpayer's future income
• An expansion of the allowable living expenses which offset monthly income 

In order for the IRS to accept a taxpayer's OIC, the IRS must believe that the amount owed by the taxpayer cannot be paid in either a lump sum or through a payment arrangement.  In order to make this determination, the IRS looks at the taxpayer's Reasonable Collection Potential (RCP).  This RCP is the minimum that the taxpayer should offer to settle a liability and it is calculated through a two part formula (1) Future Remaining Income and (2) Total Available Assets.  

• Future Remaining Income

In order to determine Future Remaining Income, the IRS reviews the household income and allowable living expenses of the taxpayers.  If the taxpayer has income left at the end of the month after all allowable living expenses are accounted for, the IRS will require that this Future Remaining Income be paid as part of the offer.  Prior to these changes, the IRS would multiply this income by 48 or 60 months (depending on whether the offer could be paid in less or more than five months respectively).  Now the IRS will only look at one year of future income for offers paid in five or fewer months and two years of future income for offers paid in six to 24 months.  

What this change means is that before, a taxpayer with $500 left over at the end of the month would have to offer at least $24,000 to settle a liability.  Now this taxpayer will have to offer at least $6,000. 

In addition, the IRS has expanded the allowable living expenses to include credit card payments, bank fee charges and minimum student loan payments.  Furthermore, the IRS will also allow the repayment of state and local delinquent taxes, based on the percentage basis of tax owed to the state and IRS.  

What this means is that if a taxpayer owes the state $25,000 and the IRS $100,000, the taxpayer owes the state 20% of the total liability and the IRS 80% of the total liability.  If the taxpayer has $500  of disposable income per month, the IRS will allow $100 towards the repayment of state delinquent taxes. 

• Total Available Assets

The IRS requires that the taxpayer include all equity (less a quick sale discount for some assets) in assets owned by the taxpayer as part of the offer.  

While this second step appears straightforward, the IRS also includes the value of dissipated assets into the calculation of the RCP.  A dissipated asset exists "where it can be shown that the taxpayer has sold, transferred, encumbered or otherwise disposed of assets in an attempt to avoid the payment of the tax liability or used the asset or proceeds (other than wages, salary, or other income) for other than the payment of items necessary for the production of income or the health and welfare of the taxpayer or their family, after the tax has been assessed or within six months prior to the tax assessment."

For example, if a taxpayer has a 2007 tax liability with the IRS and sold his or her business in 2009, the taxpayer will have to provide an extensive and detailed accounting to the agent showing that the proceeds from that sale were used for the production of income (i.e. invested in a new business) or for necessary living expenses.  

As part of the new changes, the IRS states, that it can generally go back only three years to include dissipated assets, including the year of submission.  If the offer is submitted in 2012, assets dissipated prior to 2010 will not be included.  Nevertheless, this change is subject to exceptions where it may be appropriate to include the value of the asset dissipated more than three years ago.  The IRS provides several examples of these situations which, it notes, are not exclusive. These include:

• The dissolution of an IRA to pay for a child's wedding 
• The refinance of a house where the funds were used to pay credit card debt incurred during an extravagant vacation 
• The sale of real estate where the funds were gifted to family members 

Overall, it appears that the determination of whether dissipated assets should be included in the offer amount should be evaluated on a case by case basis and is up to the discretion of the individual agent assigned to the offer. As a result, these changes would still require the taxpayer who sold his business in 2009 to provide an accounting that shows that the proceeds were used for the production of income or for allowable living expenses.  This is evident from the examples provided by the IRS of situations in which the value of an asset should not be included:

• The dissolution of an IRA during unemployment or underemployment where a review of available sources verifies that the taxpayer's income was insufficient to meet necessary living expenses
• The disposition of an asset and use of the funds to purchase another asset which is included in the offer amount.  

Although the changes relating to dissipated assets appear to have little effect on the OIC process, hopefully, these changes will at least make it easier for taxpayers to avoid inclusion of these assets where the income actually was used to pay for necessary living expenses or the production of income.  

Regardless, the changes made to the calculation of Future Remaining Income should make a substantial difference in the amounts and types of offers that will be accepted.  

This content is not intended as legal advice, and cannot be relied upon for any purpose without the services of a qualified professional. 

Trying to Leave California? Maybe Not: An Overview of California Residency Rules

If you intend to leave California and make another state or country your permanent home, avoiding California income taxes may be more difficult than you think.  Even if you do not live or earn income in California, you may be held to be a resident of California (or at the very least you may have to prove to California that you are a non-resident). 

If you file a California income tax return and claim that you are a non-resident of California, The Franchise Tax Board ("FTB") may conduct a residency audit. During this audit, you may be expected to provided (1) records detailng the purchase, sale or lease of real property (2) vehicle and vessel registration (3) Business activity information (such as employment contracts and travel logs) (4) Finacial records (including bank and credit card statements) and (5) records and information about your voting history and which service providers you have retained (i.e. doctors, attorneys, accountants, etc). 

Furthermore, if you do not file an income tax return in California and the FTB determines that you have some connection with the state of California, the FTB may prepare a proposed assessment of income taxes on your behalf.  If, for example, you hold a contractor's license in the state of California but do not live here, the FTB may estimate a reasonable salary for a contractor in California and assess taxes on this salary.  Examples of other contacts include: other licenses, owning a home, a vehicle or the payment of mortgage interest in California.  Once a proposed assessment has been filed, you must either contact the FTB and convince them that you are not a resident of California or file a nonresident tax return (which could be subject to a residency audit).  A successful determination that you are not a resident for one year may not prevent the FTB from preparing a proposed assessment on your behalf for the following year for the same reason.  

California defines "resident" as "every individual who is in this state for other than a temporary or transitory purpose and every individual domiciled in this state who is outside the state for a temporary or or transitory purpose."

The FTB claims that "the underlying theory of residency is that you are a resident of the place where you have the closest connections." The FTB has a list of factors to determine your residency status.  

1. The amount of time you spend in California versus the amount of time you spend outside of California.  
2. The state where your spouse and children are located
3. the state where your principle residence is located 
4. The state that issued your driver's license
5. The state where your vehicles are registered
6. The state where you maintain your professional licenses
7. The state where you are registered to vote
8. The location of the banks where you maintain accounts
9. The origination point of your financial transactions 
10. The location of your medical professional and other healthcare providers, accountants and attorneys
11. The location of your social ties, such as your place of worship, professional associations, social clubs and country clubs where you are a members. 
12. Location of your real property and investments 
13. Permanence of your work assignments in California. 

What does this mean for you if you have decided to leave California and take up residence in another state or country? This means that you have to substantially sever your connections with California when you leave and establish significant connections with the new state or country.  You may not maintain connections in California in readiness for your return.  

For example, you obtain a job opportunity in Arizona, leave California and move to Arizona on January 24, 2012.  Instead of selling your California home, you decide to keep it as a vacation home for when you come visit your grown children and friends.  You have an account with a California bank which you do not close. Your driver license does not expire for another three years and you make no effort to cancel it.  You also make several trips a year to visit your family and friends in California and, while there, you visit your regular doctor and/or dentist.  Under this fact pattern, if you are audited by the FTB, it may be determined that you are a resident of California for the 2012 tax year because you have maintained your connections in California in readiness for your return.  (These facts are similar to that of in the Appeal of Nathan H. and Julia M. Juran, where it was determined that Mr. and Mrs. Juran were residents of California).  

Those who are present in California for a vacation or a business transaction, are not automatically considered residents.  Nevertheless, when the visit becomes for other than a temporary or transitory purpose, you become a California resident.  This purpose could include being assigned to an office in California for an indefinite period or an indefinite recuperation period from an illness or injury. In addition, being present in California for more than nine months creates a rebuttable presumption that you are a California resident.  This is regardless of whether you also have connections with another state and consider yourself a true resident of that state (i.e. your wife and children remain in Arizona).  

In conclusion, if you intend to leave California, your intent to leave and make another place your permanent home is not enough.  Instead, California looks at whether the physical facts demonstrate that you have have relinquished your California residency.  Likewise, if you are present in or have contacts with California but consider yourself a resident of another state, you may still have to convince the FTB that you are not a resident and therefore are not subject to California income taxes.  

This content is not intended as legal advice, and cannot be relied upon for any purpose without the services of a qualified professional.  

S.B. 459: California's Attack on the Independent Contractor Classification

It is not uncommon for business owners to avoid paying taxes and employee benefits (i.e. overtime pay) by hiring independent contractors instead of employees. These business owners are already at risk of an audit by the Employment Development Department and the IRS.  If the audit ends up in a reclassification, the business owner will be responsible for unpaid taxes, possible penalties and interests.  

Now, as a result of new California legislation, this practice of misclassifying workers can end up costing business owners and their advisers everything.    

• S.B. 459

As of January 1, 2012, the California Legislature enacted a harsh new law targeting the misclassification of workers as independent contractors by California business owners. Under S.B. 459, a business owner can be found to have engaged in the following unlawful activities:

1. The "willful misclassification" of an individual as an independent contractor and/or
2. Charging a willfully misclassified worker a fee, or making any deductions from compensation for any purpose that would have violated the law governing deductions from pay (Labor Code sections 221 and 224) had the worker properly been classified as an employee.  

Additionally, non-lawyer consultants are subject to joint liability for knowingly advising a business owner to classify a worker later determined to be an employee.

• Penalties

This laws allows California's Labor Commissioner or a court to levy a civil penalty of $5,000 to $15,000 for each violation found "willful." If it is also determined that the business owner engaged in a pattern or practice of "willful misclassifications" a civil penalty of $10,000 to $25,000 may be imposed. 

Additionally, this law also empowers the Labor Commissioner to assess additional damages of behalf of those misclassified (the workers themselves). As a result, if a business owner misclassifies a large group of workers as independent contractors, the business owner may be subject to a class action law suit by this group.  

• "Willful"

The key word here is "willful". "Willful misclassification" is defined as "avoiding employee status for an individual by voluntarily and knowingly misclassifying that individual as an independent contractor." Although this standard appears to be more stringent than the "voluntary and intentional" standard proposed in earlier versions of the law, it is still problematic because courts have defined "knowing" to included constructive knowledge. As a result, if it is found that the business owner should have known that the worker should have been classified as an employee, the misclassification will be found willful.  This is a very vague and subjective standard that will cause a lot of uncertainty and is unlikely to protect business owners who are simply mistaken about the proper classification.  

• Notice

In addition to the penalties, the law also requires the business owner to post a notice (either on its website or place of business accessible to all employees and the general public) at each location where a violation occurred.  This notice must contain the specific information about the violation, be signed by an officer and be posted for one year.  

In sum, this new law imposes potentially crippling and humiliating penalties upon California business owners who improperly classify their workers. Since the standards for determining whether a worker is an independent contractor or an employee are also often subjective, this law will likely excessively burden California business owners.  If the goal of the California legislature is to inflict fear in California business owners and thereby do away with most independent contractors, the new law will most likely succeed.  

This content is not intended as legal advice, and cannot be relied upon for any purpose without the services of a qualified professional.  

What You Should Know If You Have A Foreign Bank Account

Currently, the IRS considers international tax enforcement its top priority. Therefore, if you have a foreign bank account, it is extremely important to be aware of your reporting requirements or else be subject to substantial penalties and criminal prosecution.

• The 2012 Offshore Voluntary Disclosure Program ("OVDP") 

On January 9, 2012, the IRS announced its third OVDP.  The purpose of this program is to help people with undisclosed income from foreign accounts become current with their US tax obligations.  The IRS has not yet released additional guidance to assist taxpayers in participating in this program and there is no deadline to participate (currently the guidance in existence is from the 2011 OVDP). 

Only those taxpayer who are not currently under civil or criminal investigation by the IRS may participate in this program. 

For those who choose to participate in this program by making a voluntary disclosure, the IRS promises that significant civil penalties and criminal prosecution will not be imposed.  In order to participate:

1. The taxpayer must file FBARS (see below) and amended income tax returns for the last eight years
2. The taxpayer must pay all income tax owed to the U.S.  plus a 20% accuracy-related penalty and interest for the eight years of returns 
3. The taxpayer must pay 27.5% of the highest aggregate balance in the undeclared foreign account during the past eight years.  There are exceptions to this rule.  

• FBARS

U.S. persons must disclose their financial interests in, signature authority over or other authority over, foreign bank, security or financial accounts if the aggregate value of each account(s) exceeds $10,000 at any time during the year.  This requires the filing of a Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts ("FBAR").  The FBAR is an information return which is filed separately from the taxpayer's income tax return.  The deadline to file an FBAR is June 30th. 

If the IRS determines that a taxpayer's failure to file this form is willful, the IRS can impose substantial civil and criminal penalties.  If the violation is not willful, the penalty shall not exceed $10,000 per violation.  If the failure to file is due to reasonable cause and the account was properly reported, no penalty should be imposed.  

For each willful violation, the IRS shall impose a penalty which is the greater of $100,000 or 50% of the value of the account at the time of the violation (the time of the violation occurs on the due date for filing the FBAR).  A willful violation also subjects the taxpayer to five years in prison and/or a maximum fine of $250,000.  

This content is not intended as legal advice, and cannot be relied upon for any purpose without the services of a qualified professional.  

Voluntary Worker Classification Settlement Program: A Fresh Start for Employers

As part of its effort to provide a "Fresh Start" to taxpayers and businesses, the IRS created the Voluntary Classification Settlement Program (VCSP)  to allow employers to voluntarily reclassify their workers (or a class/group of workers) as employees for future tax periods.  

Many employers erroneously miss-classify their workers as independent contractors or non-employees.  Whether a worker is actually an employee or an independent contractor depends on the facts and circumstances involved.  Nevertheless, the classification issue is most often resolved based on whether the employer has the right to direct and control the worker as to how to perform the services.  There are many situations where correct classification is unclear.  

If the employer is audited and the independent contractors or non-employees are reclassified as employees, the employer will face a substantial tax liability, including interest and penalties, for three years of employment taxes. The VCSP allows employers to avoid this possibility by giving them the chance to preemptively reclassify workers.  The VCSP builds on the Classification Settlement Program (CSP) that has already been in place for years.  The CSP is available to employers already under IRS examination and allows prospective reclassification of workers as employees with reduced federal employment tax liabilities for past non-employment treatment.  The VCSP, on the other hand, allows taxpayers to reclassify without first going through the burden of an examination. 

The employer does not have to reclassify all workers in order to be eligible under the VCSP.  Nevertheless, if specific workers are reclassified as employees, all workers in the same class must also be treated as employees.  

In order to be eligible to participate in the VCSP, the employer: 

• Must have consistently treated the workers or a class/group of workers in the past as independent contractors or non-employees
• Must have filed all required 1099s for the workers for the previous three years.  These 1099s must have been filed within 6 months of their due dates (including extension) to qualify as having been filed.  
• Must not currently be under audit by the IRS, the Department of Labor or a state agency concerning the classification of these workers.  If the employer has previously been audited regarding the classification of the workers, the employer must have complied with the results of the audit in order to be eligible. 

In order to participate in this program, Form 8952 must be filed at least 60 days before the employer wants to being treating the workers as employees.  The taxpayer should also provide the name of a contact person or authorized representative with a valid Power of Attorney.  The IRS will contact this person in order to complete the VCSP process. 

If the employer is accepted into the VCSP, the employer will enter into a closing agreement with the IRS to finalize the terms of the agreement and make full payment of the amount due.  

If accepted into the program, 10% of the employment tax liability that would have been due on compensation paid to the worker (or class/group of workers) for the most recent tax year must be paid.  This amount is determined under the reduced rates of section 3509(a) of the IRC.  Interest and penalties will not be assessed and the employer will not be audited on payroll taxes with regards to these workers for past years.  

Under section 3509(a), the tax rate for compensation up to the Social Security wage base is 10.28% in 2011 and 3.14% for compensation above the Social Security wage base.  Currently, the most recently closed tax year is 2011 so the 10.28% rate applies.  

For example: if in 2011 an employer paid $100,000 to workers that the employer wishes to reclassify under the VCSP, the employment taxes applicable to the $100,000 would be $10,280.  10% of this amount is $1,028.  (In this example all workers were compensated below the Social Security wage base). 

The employer must also agree to be subject to a special six-year statute of limitations (rather than the usual three years) for the first three years under the program.  

The IRS promises not to share information about an employer's participation in the VCSP with the Department of Labor or with any state agencies.  Furthermore, the IRS states that a rejection of the form 8952 will not automatically trigger a Federal audit.  

This content is not intended as legal advice, and cannot be relied upon for any purpose without the services of a qualified professional.  

The IRS "Fresh Start" Initiative: Expanded to Help Struggling Taxpayers

Since 2008, the IRS has been adjusting its collections practices to help struggling taxpayers during this difficult financial climate.  

Part of these efforts is the "Fresh Start" initiative, announced on February 24, 2011.  The changes included in this initiative are: (1) Adjustments to Lien Polices (2) Easier Access to Installment Agreements for Struggling Small Businesses and (3) Expanding the Streamlined OIC Program.

Last week, the IRS announced a major expansion of this "Fresh Start" initiative.  As part of this expansion, the IRS is taking steps to provide new penalty relief to the unemployed and allowing even more taxpayers to qualify for an installment agreements.

Adjustments to IRS Lien Polices

Under the Fresh Start Initiative, the IRS will no longer file a lien if the tax owed is under $10,000 (unless special circumstances warrant otherwise).  

After a lien has been released because the tax liability has been satisfied, a taxpayer may request a withdrawal in writing by submitting form 12277. 

Furthermore, a taxpayer who owes $25,000 or less will be eligible for a lien withdrawal if he or she sets up an installment agreement through direct debit and makes three consecutive direct debit payments.  

Installment Agreements for Businesses

Small business that owe $25,000 or less in payroll tax, can set up an installment agreement without submitting a financial statement if the installment agreement allows for the debt to be paid within 24-months and the installment agreement is set up through direct debit.

Offer in Compromise

The streamlined OIC program is available to wage earners, the unemployed and self-employed taxpayers with no employees and gross receipts under $500,000.  A taxpayer is eligible for this program if his or her total household income is $100,000 or less and the amount owed to the IRS is less than $50,000.  If the taxpayer qualifies for this program, fewer requests will  be made for additional financial information and there will be greater flexibility in calculating a taxpayer's reasonable collection potential.  

Following the initial expansion of the streamlined OIC Program in 2011, the IRS has been working to put in place additional common-sense changes to the program to reflect real-world situations. 

  

Relief From Penalties 

The IRS plans to allow a six-month grace period on failure-to-pay penalties for certain wage earners and self-employed individuals.  In order to qualify, the taxpayer must fit into one of the following categories:

• Wage earners who have been unemployed for at least 30 consecutive days during 2011 or in 2012 (from January 1-April 17 2012).  
• Self-employed taxpayers who experience at least a 25% reduction in business income in 2011 as a result of the economy.  

Furthermore, the taxpayer's income must be equal to or less than $200,000, if filing married filing joint, or $100,000, if filing single or head of household.  The taxpayer's balanced owed for 2011 must also not exceed $50,000.  If these eligibility requirements are met, taxpayers need to complete Form 1127A in order to request relief.  

If the tax, interest and other penalties are fully paid by October 15, 2012, a request for an extension of time to pay will shield the taxpayers from the failure to pay penalty for 2011.  

Interest, which is currently 3% per year, is not affected by this grace period and will continue to accrue on unpaid back taxes.  

Installment Agreements

The IRS has also expanded the streamlined installment agreement process to allow individual taxpayers who owe $50,000 or less to request an installment agreement without having to submit a financial statement.  The maximum term for payment has also been raised to 72 months.  In order to qualify for for this expanded streamlined installment agreement, taxpayers must agree to pay through direct debit.  

This content is not intended as legal advice, and cannot be relied upon for any purpose without the services of a qualified professional. 

Unreasonable Expectations: Offer in Compromises and Tax Liens

While I was watching a YouTube video earlier today, an advertisement for Tax Resolution Services ("TRS") popped up. This was the first time that I heard of this company so I decided to do a Google search for reviews. A preliminary search revealed a B+ BBB rating due to 39 complaints filed. Eventually, during my search, I came across a website called Complaints Board and found the following review: 

"I hired TRS over 3 years ago and they have yet to have my case resolved. I paid $5,000 to have an Offer in Compromise submitted (that's already .25 cents on the dollar). They accepted payments over a 10 month period, but did no work at all until the entire amount was paid. My case has now been in appeals process with IRS since October of 2008. My current case rep at TRS (it has changed 5 times) tells me the IRS is the reason for delay. As of Aug 1, I now have to pay an additional fee of $1,500 or they will no longer represent me. This is not right. I can not believe they do nothing and then charge you for what are supposed to be IRS delays. Additionally, they did not stop (nor did they make any attempt to stop) the IRS from issuing a Tax Lien that appears on my credit reports. So, after 3 years, still carrying a monkey on my back, my credit is in the toilet, and the company that is contracted to resolve the issue is demanding more money - immediately." (submitted August 17, 2009). 

Although I don't know the exact circumstances of this case and all the facts involved, two issues in this complaint immediately jumped out to me as worthy of explanation: (1) the delay with the Offer in Compromise ("OIC") and (2) failure to stop an IRS lien.  

Offer in Compromise Delays 

These two issues reflect the unreasonable expectations of many taxpayers. First of all, the OIC process takes a very long time. The acceptance of an OIC is not a right, it is an exception to the general rule that taxpayers have to pay their taxes. This reviewer sounds extremely shocked at how long this OIC process has taken. Well, it can take a long time and IRS representatives can be very unresponsive.

After an OIC is submitted, it takes anywhere from six months to a year before a representative contacts you for additional information. If the representative decides to reject the OIC, and many of them do, an appeal should be submitted. It takes about another six months or more for a new representative to be assigned to the case. These representatives are IRS Appeals Agents who are swamped with cases. For example, I submitted an appeal for my client's OIC near the end of August 2010. I was contacted by an Appeals Agent in March of 2011. After all the documents requested by the agent were submitted and all the issues dealt with, the agent stopped returning my calls. I began calling and leaving her voice mails once a week. Eventually, after no call back, I left monthly voice mails. This OIC was finally accepted on January 19, 2012.

Tax Lien Prevention 

The other issue that I want to address is this reviewer's complaint that the company "did not stop (nor did they make any attempt to stop) the IRS from issuing a Tax Lien." The IRS almost always files a tax lien if a debt is owed and it is almost impossible to prevent the IRS from issuing the lien. The lien is there to protect the government's interest in the tax debts owed to it. 

In order for the IRS to release the lien, the debt must either be paid in full (or a bond is submitted that guarantees payment of the debt in full) or settled through an OIC. Additionally, if your tax debt is less than $25,000 and you set up a direct debit installment agreement (monthly payments will be withdrawn from your checking account), you can request that the IRS withdraw the lien after three months of successful payments. 

The other option is to wait for the collections statute of limitations ("SOL") to expire. The IRS has 10 years from the date of assessment to collect the taxes owed. Nevertheless, this SOL can be extended by a number of actions including, the filing of an OIC, bankruptcy, a formal request for an installment agreement and a voluntary agreement to extend the SOL. While this SOL is running, unless you have an installment agreement with the IRS, the IRS will do everything in its power to collect what you owe.  If they can, they will garnishing your pay check and take money out of your bank account.  

Since I don't know the specifics about this reviewer's billing complaint, I don't want to go too much into this issue.  This billing problem is probably the main reason that this customer posted this complaint.  If this reviewer had a flat fee agreement of $5,000 with TRS to submit the OIC, it was not right for this company to demand the extra $1,500 by threatening to terminate representation. Why they did so I do not know. 

It also does not seem right that the company waited to receive all the payments before they began working on the OIC.  Nevertheless, if this reviewer was informed beforehand that no work would be done before the balance was paid, she should not be complaining about the deal she agreed to.  Also, I do not know how much preliminary disclosure this reviewer received from TRS.  It is important for a tax professional to inform the client that the OIC process is burdensome and long and why tax liens will be filed.  Disclosure, frequent communication and flexibility in dealing with billing problems prevents clients from getting frustrated when their case does not go as planned. 

In conclusion, there are companies out there that take advantage of taxpayers and the OIC process.  Whether TRS is one of them, I don't know.  The company has bad reviews but so do other legitimate companies and attorneys.  I am not making a recommendation about the legitimacy of this company. If you are considering hiring this company, I recommend that you read the reviews yourself before you make a decision.  

This content is not intended as legal advice, and cannot be relied upon for any purpose without the services of a qualified professional.