Clinical Work Combines Accounting with Legal Knowledge

For Villanova Law student Seth Wasserman '23, navigating the complex American tax system is second nature. A native of Broomall, PA, Wasserman was taught from a young age how to manage money. His father, a CPA who prepares personal income taxes, inspired him to earn his BA in accounting from Muhlenberg College in Allentown, PA. Wasserman went on to work in public accounting for Deloitte for a year as an audit associate before beginning at Villanova Law.

After completing his 1L year, Wasserman had the opportunity to combine his financial literacy background with his legal knowledge. During the summer of 2021, he worked as a student attorney in Villanova Law’s Federal Tax Clinic, one of six in-house legal clinics at Villanova Law where students provide pro bono legal representation to low-income individuals in dispute with the IRS.

"I was excited to put my accounting degree and background to work in the legal sphere to help clients in need," said Wasserman. "It was a natural fit for me and gave me my first taste of legal tax work."

Over the course of the summer, Wasserman worked with multiple clients serving as their primary advocate and taking on direct responsibility for their cases. He worked closely with one client in particular whose tax debt was recently paid off after years of dispute with the IRS.

The client, a retired musician, came to the Federal Tax Clinic for help in 2019. After being audited by the IRS in 2014, she owed more than $9,000 and was under scrutiny from a third-party debt collector. As a wedding band leader for many years, she had collected the entire amount owed to the band and then paid the other band members. Unfortunately, when she was audited, she was unsuccessful at proving her real income, so the IRS taxed her on the gross payment she had received for the entire band instead of her individual earnings.

Unable to pay the IRS, she lived on the verge of homelessness and made minimum balance payments to the collection agency. She had retired from playing gigs and was making poverty wages in another position. When Federal Tax Clinic students took on her case, they negotiated directly with the IRS to place her in "Currently Not Collectible" status due to financial hardship. This protected her from the collection agency and stopped the IRS from collecting the balance due, but she continued to accrue interest and penalties.

Wasserman researched possibilities for permanently resolving the debt. After weighing the options and the likelihood of getting years-old documents and receipts from wedding planners and bandmates, the client decided to pursue an "Offer in Compromise" with the IRS. Wasserman helped compile the "Offer in Compromise" package, which required detailed information on the taxpayer’s income, expenses and assets, demonstrating that she was not able to currently pay the debt and would remain compliant with her taxes in the future.

"I worked directly with my client helping to explain the basic functions of the IRS," said Wasserman. "Even though she was an adult who had worked for many years, this process was new to her, and she was very fearful of the IRS. It was an eye-opening experience for me to learn how daunting the IRS can be to people who don’t have basic knowledge of finance and accounting and have never been educated on the tax system."

Thanks to Wasserman and other Federal Tax Clinic student attorneys, the IRS agreed to write off over 80 percent of the client’s balance. She was thrilled with the result and happy to have her tax burden resolved. Wasserman helped her brainstorm creative ways to pay off her remaining balance, which she did in February 2022. Wasserman then helped set her on the path to be successful with tax payments in the future.

Wasserman's work in the clinic proved to be transformative and helped to define his future career plans. "After working one-on-one with clients, it has solidified my desire to personally advocate for individuals and their families." Following graduation from Villanova Law, Wasserman hopes to practice in trusts and estates and eventually pursue a master of laws in taxation (LLM) degree.