Our tax controversy practice group provides expertise in representing taxpayers in administrative tax audits and disputes with the IRS and all state tax agencies.
Although we have the knowledge and experience to represent the taxpayer through each administrative and legal channel, we make every effort to resolve cases early in the tax controversy process in order to minimize our clients’ exposure to additional tax liabilities and professional fees and costs. We take pride in developing and managing focused audit defense strategies aimed at achieving extraordinary favorable results for our clients.
Our tax attorneys and tax professionals include former IRS and tax agency representatives who are intimately familiar with governmental administrative procedures for handling tax disputes before the Examination Division and Appeals Office of the Internal Revenue Service as well as all state tax agencies charged with administering income taxes, employment and payroll taxes, sales and use taxes, excise taxes, property taxes and corporate income and franchise taxes imposed by each state. Many times, our tax professionals have formed strong working relationships with the IRS and state taxing agency personnel which often facilitates favorable results.
Our team of tax professionals consider strategic and tactical issues throughout the audit process involving the statute of limitations, timing and location of field audits, informal and formal document requests directed toward the taxpayer and third parties (and responding and objecting to such requests), obtaining information from the IRS under the Freedom of Information Act (FOIA) and other means, partnership audit procedures, and a host of other issues and special examination procedures.
We routinely represent and advise taxpayers in complex and sensitive civil tax matters involving exposure to substantial additional tax, penalties, and interest. These tax controversy matters often include unreported income and non-filer cases, tax fraud and evasion cases, innocent spouse relief cases, comprehensive payroll tax audits involving worker classification, sales, use and excise tax audits, trust fund recovery penalty assertion cases, foreign bank account report (FBAR) matters, state residency related tax issues regarding domicile, business tax issues involving corporations, partnerships and other entities, penalty abatement requests and a variety of other tax related disputes.
Administrative Appeals serves to resolve taxpayer disputes by offering a somewhat independent review of the audit examiners determinations or adjustments. Unlike Revenue Agents or Tax Auditors, Appeals Officers will consider the government’s “hazards of litigation” through the taxpayer’s submission of a Protest Letter (including supporting documentation). To aid settlement discussions and obtain the greatest number of government concessions through the administrative Appeals process, we prepare a well drafted Protest which outlines the relevant facts and legal analysis supporting the taxpayer’s position if we determine this process is a viable step forward.
At the conclusion of the administrative Appeal process, if the case remains “Unagreed,” the IRS issues a Statutory Notice of Deficiency which permits the taxpayer to challenge the adjustments proposed by the IRS by litigating them in the United States Tax Court. If that occurs, we are prepared to represent our taxpayer clients vigorously in court.
Monday-Friday: 8AM to 8PM
Saturday: 10AM to 6PM
Sunday: Closed