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Hayley Greenberg

Jerry Merola


Hello. I have been practicing tax law for over 30 years. I have successfully handled IRS cases, tax cases in different states and municipalities like New York State and New York City. I am a former New York City Senior Tax Counsel where I litigated numerous substantial tax cases for the Department of Finance.

I can help you with:
  • Municipality tax problems (like NYC)
  • State tax problems
  • IRS tax problems
  • State/Federal audits
  • Late or missed filing of tax returns
  • Penalties & late fees
  • Offers in compromise
  • Tax fraud
  • Employment taxes
  • Settlment and payment plans
  • Sales tax issues
  • Business taxes
  • And other issues

I am very familiar with the rules and requirements of many New York City agencies which can be a great advantage to you.

My team of lawyers and paralegals know what they are doing to help you. I work with all my lawyers individually and personally so you get the best representation.

I am in court on a regular basis and know how to help you and guide you with what is best for your case. And I am fully familiar with the Courts so I know how they operate and the individual rules and quirks associated with them.

With my many years of experience I have seen all kinds of problems like yours and I can usually come up with a way to solve them.

One of the most important ways to win your case is to know the law. I am a Continuing Legal Education teacher and I teach other lawyers about tax law.

It is very important that you choose an experienced and knowledgable lawyer like myself to help you through one of the most stressful and painful times in your life. Call me today and we can start figuring out the best strategy for your case. To save some time, try to have some of your documents and/or dates ready before you call. Jerry Merola


IRS audit rates are finally going down after having gone up as the IRS had put funds into updating computers, customer service and other programs. When the reorganization was over the IRS was back to enforcement with a vengeance. However, recently the rates have lowered.

For example during 2003 the audit rate for all individual tax returns rose 14%, the audit rate for taxpayers with incomes over $100,000 rose by 31%.

But for 2019, they audited 0.45% of individual tax returns down from 0.59% in 2018, and down by more than half from what it was in 2010, when 1.11% of taxpayers were audited.

Seizures, liens and levies had risen too! In 2003, seizures rose 539% of what they were in 2000, liens rose 327% and levies rose 765%.

However, in 2018 the IRS published their Data Book which showed significant declines due to a shrinking budget and less staff. But, when you start with such a large budget even a decline in liens results in thousands of problems!

Over the years, The IRS has begun doing much more to audit smart like national research programs so they can select audit targets with greater effectively like computer matching programs for K-1s to find income paid by partnerships, S corporations and trusts to taxpayers.

Offshore transactions are made a high priority and the IRS is aggressively pursuing those who use foreign bank accounts to escape taxes. Another high priority target is abusive tax shelters which have been promoted on the internet.

Specifically targeted: Those with “total positive income before taxes but low net taxable income after deductions.

The IRS also has new information-sharing programs with states for use in shelter cases and others to detect tax evasion.

What can we do for you?

We can review the assessment by the IRS to see if they made any mistakes in calculations or in the application of the law to reduce your deficiency. As a former Tax Counsel for the Department of Finance I know there are many mistakes that can be made at the Audit level.

We can make offers to settle the matter and if that doesn’t work; we may appeal the auditor’s decision to his superior. The agents are under pressure to close cases so they don’t want too many cases to be appealed as this doesn’t look good on their performance review.

We may make an Offer in Compromise to the IRS, that is offer to pay less than the assessment because you cannot make or ever make payment.

We may offer to pay off the deficiency in installments as that may be much easier for you.

If we are convinced that we can get a better deal form the IRS, we will tell the Service that we are filing with the Tax Court for a trial. This usually has the effect of getting a settlement offer accepted.

There are more strategies for dealing with the IRS; let us explain them to you.

Do you have tax problems? Or do you simply want professionals to prepare your returns? If so, consult the experts. Greenberg & Merola, LLP has CPAs associated with our firm to help give you the correct expert advice you deserve!

FREE OFFER: Call today and request the reports we publish. DON'T LET TAX PROBLEMS HOLD YOU BACK!

Call today for FREE 5 SECRET TAX TIPS on what business owners can do to end IRS difficulties.

Call today for FREE CONFIDENTIAL IRS TAX REPORT on what you can do to end IRS problems.


NYS TAXES - Our client had a restaurant in New York City for many years. Due to very tragic circumstances he fell behind in paying the sales tax to the NYS Dept. of Taxation. He received a close and padlock business notice and came to us for help with only days to spare before he lost his livelihood. We were able to get NYS to cease and desist and worked out a compromise that reduced his tax liabilites from approximately $150,000 to $36,0000. And he was able to spread out the payments over many years so he could keep the family business going. This is approxiamtely 24 CENTS ON THE DOLLAR.

IRS TAXES - Our clients a married couple live in New York and had a small family business. Unfortunately, they failed to pay their personal income taxes and their business employment taxes. They went to the IRS and were told to pay approximately $150,000 in one payment. There is a Statute of Limitations for 10 years. Then they came to us and we recalculated what was owed and made an offer and compromise which was accepted for $25,000. That is approximately 16 CENTS ON THE DOLLAR. And we got them a 24 month payout period.

IRS TAXES - Our client came to us who owed over $15,000 to the IRS and they were taking his low income via a wage execution. We showed the IRS that he was in a 12 step program and trying to get his life back on track and that is why he was not able to make a full payment to them. We got them to agree with us and they took $1,500! An amazing 10 CENTS ON THE DOLLAR.


Jerry Merola started a Tax Alerts Newsletter which is distributed to several thousand Judges througout New York State and attorneys, free of charge.

Click on the newsletter you want to open for an easier read.

Contact us for new clients only. Existing clients please call.

Call today to see if your plan is one of them

GREENBERG & MEROLA, Attorneys at Law
521 5th Avenue, Suite 1700, New York, NY
2280 Grand Avenue, Suite 2280, Baldwin, NY
Conference Offices: Nassau, Brooklyn, Queens, Westchester, Bronx, Suffolk

521 5th Ave., Ste. 1700, New York NY

2280 Grand Ave., Ste. 202, Baldwin NY

26 Court St., Bklyn NY

1129 Northern Blvd., Manhasset NY

214-11 Northern Blvd., Bayside NY

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547 N. Ave., New Rochelle NY

749 E. 135th St., Bronx NY

150 Motor Pkwy., Hauppauge NY

Prior results do not guarantee a similar outcome. Attorney Advertising. This website provides general information. Due to complexities and constant changes in the law, exceptions to general principles of law, and variations of state laws, seek professional legal advice before acting on any matter!

Some of the information on this website only pertains to certain states. Accordingly seek professional legal advice before acting on any matter.