Tax Controversy & Tax Audits
Our tax attorneys have assisted our individual and business clients in all types of federal and state tax controversies, including audits, administrative appeals, tax court litigation, collection appeals hearings and the offer-in-compromise process. Some of the more common issues we help our clients address are disputes arising over:
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Disallowance of Business Expenses
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Fraudulent Conveyances
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“Hobby Loss”
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Innocent Spouse
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Unreported Income
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Collection Actions
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Federal Tax Audits
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State Tax Audits
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Tax Lien to Judgment
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Shareholder Basis
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Civil Fraud Penalty
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Collection Due Process
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Employee/Independent Contractor Status
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Liability for Trust Fund Recovery Penalty
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Freedom of Information Act Requests
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Non-Filers/Estimated Tax Assessments
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TAX AUDITS
Our Tax Controversy lawyers understand that an efficient and successful resolution to tax controversies often begins with skillful representation before court involvement. We assist clients with small & large case audits, in answering IDRs, in dealing with IRS agents and in formulating overall audit strategies. Our role in the audit depends on the needs of each individual client and the circumstances of each case, including the intensity of IRS counsel's activity in the audit. In some audits, we have played a lead role at the request of the taxpayer, in effect managing the entire audit; in others, we have served a purely advisory role, staying in the background with no direct contact with the IRS.
ADMINISTRATIVE APPEALS
Our tax lawyers have handled many cases in the IRS Appeals Office and have substantial experience negotiating with IRS Appeals officers and representing taxpayers before Appeals. We have also participated in the Fast Track mediation process with IRS Exam, which involves using IRS Appeals personnel as mediators. We have also been involved in negotiating with the IRS to establish arbitration and mediation procedures used as an alternative to trial for resolving cases.