The Tax Controversy Group focuses on resolving tax disputes involving the Internal Revenue Service and state taxing agencies preferably through an administrative proceeding, but when necessary, as a federal or state civil tax litigation matter.
Most tax controversies arise when the IRS or state taxing agency determines that there is an understatement of tax reported on a filed tax return or because of the taxpayer’s failure to file a return. These tax disputes may involve an individual, business (whether for-profit or not-for-profit), trust, or estate and can relate to any form of taxation - income tax, employment tax, sales or use tax, excise taxes, and property taxes. If unable to dispute the tax claim(s), we aggressively represent our clients before the collection division of the taxing agency to negotiate and compromise the tax claims, reduce penalties, or arrange for a payment plan.
The Tax Controversy Group focuses on representing tax clients and navigating administrative proceedings before the IRS Examination, Appeals and Collection Divisions of the IRS and state tax agencies to produce exceptional results. Our Tax Controversy attorneys are valued for their judgment, common sense, and depth of experience as well as their trial, negotiation, procedural, and tactical skills in resolving complicated tax disputes. We specialize in providing expertise regarding substantive tax laws, dealing with Revenue Agents, formulating audit defense strategies, and pursuing administrative appeals.
Our tax controversy attorneys and tax professionals include former IRS and taxing agency representatives who possess strong accounting backgrounds and advanced LLM degrees in taxation. We deploy our substantial knowledge and experience to effectively achieve a favorable outcome in each tax controversy case – whether that case involves an administrative tax audit, appeal, collection matter, criminal enforcement, or tax litigation.
When litigating tax disputes, the taxpayer has a choice of three different courts: the Tax Court, federal district court or the Court of Federal Claims. When deciding on the right forum, our tax litigation attorneys consider many factors including the willingness or ability to advance pay the tax, judicial precedents which make one forum more favorable than another, the need for a jury trial, exposure to new issues and an increased tax deficiency, the need for extensive discovery and burden of proof considerations. Thus, although litigation is usually the last option, if necessary, we can provide skillful representation in all court proceedings. – whether to challenge the underlying tax claim, inappropriate collection activity or recovering overpayments through refund litigation.
Most of our new client referrals are by “word of mouth” for one reason – we are aggressive and deliver amazing results. If you’re in the process of vetting tax controversy attorneys – look no further. You can count on us to communicate clearly, be fully transparent and employ effective strategies using a cost-benefit analysis while applying a complex-versus-simple approach. Schedule your free Tax Case Evaluation today!
What Sets Us Apart?
Our Tax Bankruptcy Group operates as part of a virtual tax law firm, offering our clients a positive remote experience that reduces the need for tedious face-to-face meetings, the shuffling of paperwork back and forth and the need to get together just to obtain handwritten signatures.