Most Minneapolis taxpayers with a serious tax problem are fighting on two fronts, not one. The IRS is the name everyone knows. The Minnesota Department of Revenue is the one that often moves faster, hits closer to home, and gets overlooked until a paycheck comes up short. CLAW Tax Group works both.
This is a tax resolution and defense practice, not a seasonal prep office. The work starts where most accountants stop: after the return is filed, when the notices turn into liens, levies, and garnishments. The firm represents Minneapolis individuals and businesses in front of the IRS Collections and Examination divisions and in front of MN Revenue’s enforced collection unit, and represents clients in all 50 states from its Twin Cities base.
Call or text: (651) 323-2255
When the Problem Carries Criminal Risk
Not every tax problem is just about money. Some carry the threat of civil fraud penalties or, worse, a criminal referral. Unreported income, a pattern of unfiled returns, cash businesses, badges of fraud in an audit: any of these can move a case from a collection matter into something that needs a lawyer, not just a preparer.
This is the situation where most Minneapolis taxpayers are dangerously underrepresented. A storefront tax shop is not equipped to handle fraud exposure, and by the time it becomes obvious one is needed, statements have already been made that cannot be unmade. The early decisions matter most, and they have to be made by someone who understands where the line between an aggressive audit and a criminal investigation actually sits.
CLAW Tax Group is built for this. Through the firm’s affiliation with Wildes At Law, a Minneapolis taxpayer facing potential fraud exposure gets enrolled agent representation and a licensed attorney and CPA, Matt Wildes, on the same file from the start. Enrolled agent depth handles the tax mechanics. The attorney handles the legal exposure and the privilege that comes with it. That combination under one roof is rare in this market, and it is the difference between managing a fraud-adjacent case and walking into one blind.
Two Agencies, Not One
A Minneapolis taxpayer who owes the IRS frequently owes the State of Minnesota too, because a federal adjustment usually flows down to the state return. The two agencies collect differently, and a strategy built for one can miss the other entirely.
The IRS operates under a ten-year collection statute and a federal appeals structure. The Minnesota Department of Revenue runs its own program of Enforced Collection Actions under Minnesota Statutes Chapter 270C, and it is aggressive. The state can levy wages up to 25 percent of disposable earnings, freeze and seize bank accounts, file liens, revoke a business or professional license, and pull money through Revenue Recapture, which intercepts state refunds and other payments owed to you. The state does not wait the way the IRS often does.
Knowing how both agencies move, and how a federal resolution affects the state balance and the reverse, is the difference between a tax professional who files forms and one who actually defends the case. A national resolution mill working a Minneapolis file from a call center in another state rarely accounts for MN Revenue until it has already levied.
Where We Step In
Tax fraud and criminal exposure. The cases above. Enrolled agent and attorney working together from the first decision, before anything is said that cannot be walked back.
IRS and MN Revenue audits. What gets produced and what gets said shapes the outcome. Representation means the examiner deals with the firm, not with you, and the information flow is managed.
Levies and wage garnishments, federal and state. An IRS levy or a Minnesota wage levy is not the last word. Many can be released or reduced through the right filing, but the window is measured in days. A Minnesota wage levy reaches up to a quarter of disposable pay, so the clock matters.
Unfiled tax returns and Commissioner Filed Returns. Years of unfiled federal or state returns are the most common reason a manageable balance turns into a crisis. The records get reconstructed, the back years filed, and compliance restored, which is the gate every resolution option runs through. The state side has a specific trap covered below.
Offers in Compromise and settlements. An IRS offer can settle federal debt for less than the full balance, and Minnesota runs its own settlement process. Qualification is narrow on both, and the timing interacts with the collection statute. You get an honest read before chasing one.
Installment agreements and Currently Not Collectible status. When settlement is not the answer, the goal is terms that hold up, or pausing collection while the situation stabilizes, with both agencies in view.
The CFR Problem: When Minnesota Files Your Return For You
This is the state mechanism that catches the most Minneapolis taxpayers off guard. When the Minnesota Department of Revenue believes a return is missing, it does not just send reminders. It files a return for you. That filing is called a Commissioner Filed Return, or CFR, authorized under Minnesota Statutes Section 270C.33, subdivision 3. The IRS does the same thing at the federal level with a Substitute for Return, but the state CFR process moves on its own track and trips up taxpayers who think they only have an IRS problem.
Here is why a CFR hurts. The state builds it from whatever information it has on file, usually wage and income data reported by employers and payers. It does not include the deductions, exemptions, dependents, business expenses, or credits you would actually claim. The result is almost always a liability far higher than what you truly owe. And the CFR is treated as correct by law until you replace it. Penalties and interest attach to that inflated number, and the state’s enforced collection machinery, levies, bank seizures, and Revenue Recapture, can start running against a balance you never actually owed.
A CFR does not satisfy your filing obligation. The only real fix is to file your own accurate return to replace it. That is the work: reconstruct the records, prepare the correct return with every deduction and credit you are entitled to, and file it to overwrite the state’s inflated estimate. In many cases that drops the liability dramatically, and where the corrected return shows the state was paid too much, it can produce a refund rather than a bill.
The refund window has a hard edge. To recover an overpayment after a CFR, the replacement return generally must be filed within 3 1/2 years of the original due date, or within one year of the date on the CFR notice, whichever is later. The one-year-from-CFR rule is what can keep a refund alive on an older year after the normal window has closed, but only if the return is filed in time. Wait too long and the overpayment is forfeited even though the corrected numbers prove the state was overpaid.
If the CFR is wrong on its face, there is also a hard deadline to challenge it directly: an appeal to the Minnesota Tax Court must be filed within 60 days of the Notice Date, under Minnesota Statutes Section 271.06, with an administrative reconsideration path under Section 270C.35. A Minneapolis taxpayer who opens a CFR notice and sets it aside is often the one who ends up with a levy on a number that was never real.
Who Handles Your Case
CLAW Tax Group is led by Jon Call, an Enrolled Agent, NTPI Fellow, and a contributor to national taxpayer policy through the NAEA. An Enrolled Agent is federally licensed with unlimited authority to represent taxpayers before the IRS in every state, on every matter. It is the credential built for exactly the situation a Minneapolis taxpayer with a tax problem is in.
He does not work alone. The firm staffs additional Enrolled Agents whose work is exclusively representation and resolution, not tax prep, so a Minneapolis case is handled by people who do this every day. And through the affiliation with Wildes At Law, the firm brings in Matt Wildes, JD and CPA, when a matter calls for licensed legal counsel alongside enrolled agent representation.
What Happens After You Call
Every case starts with the transcripts and the state account. The full picture gets mapped: the years, the balances, the penalties and interest, the assessment dates, the federal collection statute expiration date on each year, and the parallel position with MN Revenue. Working a resolution case without that information is working blind.
From there the strategy is built around the actual numbers, not a template. Some years may sit near statute expiration and be left alone. Others point toward an installment agreement, an offer, or a hardship filing, on the federal side, the state side, or both. The plan fits the liability, the income, and the timeline.
You hear the realistic version before committing to anything. A Minneapolis taxpayer deserves the honest read up front rather than a resolution that was never going to qualify.
By appointment only. No walk-ins. Please call ahead to schedule an in-person meeting.
The Bottom Line
A tax problem does not shrink by waiting. Penalties stack, interest compounds, and neither the IRS nor Minnesota Revenue gives back time. If you are in Minneapolis and either agency has your attention, the move is to get represented before the next notice becomes a levy.
Call or text: (651) 323-2255
CLAW Tax Group is a tax resolution firm based in the Twin Cities metro, serving Minneapolis and clients in all 50 states. Led by Jon Call, EA and NTPI Fellow, with a staff of Enrolled Agents dedicated to representation work. Affiliated with Wildes At Law, where Matt Wildes provides licensed attorney and CPA representation.
References: Minnesota Statutes Chapter 270C (collection); Minn. Stat. § 270C.33, subd. 3 (Commissioner Filed Return); Minn. Stat. § 270C.35 (administrative reconsideration); Minn. Stat. § 271.06 (Tax Court appeal); Minn. Stat. § 289A.40 (refund claim period); Minn. Stat. § 270C.69 (levy); Minn. Stat. § 270A (Revenue Recapture); Internal Revenue Code § 6502 (federal collection statute).