Litigation and Controversy - Tax Attorneys

Understanding Tax Controversy & Litigation

Tax controversy and litigation represents a significant area of legal complexity. It involves disputes between taxpayers and the Internal Revenue Service (IRS) or state tax authorities regarding tax assessments, audits, penalties, and deficiencies. These disputes can range from straightforward disagreements about interpretations of tax laws to highly intricate and lengthy legal battles.

When a tax authority issues a notice of deficiency or proposes adjustments to your tax return, it often triggers a tax controversy. The IRS may argue that you’ve inaccurately reported income, overstated deductions, or failed to comply with tax regulations. These issues can lead to substantial penalties, interest charges, and potentially significant tax liabilities.

Common Strategies in Tax Controversy & Litigation

Our experienced attorneys employ a range of strategies to address tax controversies, including:

• Negotiation & Settlement: We frequently engage in negotiations with the IRS to attempt to resolve disputes amicably and avoid costly litigation.
• Administrative Appeals: We can represent you before the IRS Appeals Office, providing a formal avenue for challenging the IRS’s positions.
• Litigation: When negotiation fails, we are prepared to litigate your case in federal district court or, in some instances, before the U.S. Tax Court.
• Fraud Examination: We investigate allegations of tax fraud and assist in gathering evidence to support your defense.
• Penalty Relief: We can challenge penalties assessed by the IRS, arguing that they were improperly assessed or are unenforceable.

Areas of Expertise

We handle a wide range of tax controversy and litigation matters, including:

• Individual Tax Disputes: Disputes involving personal income tax returns, including audits and protests.
• Business Tax Disputes: Disputes related to corporate income tax, partnership tax, and other business tax issues.
• Transfer Pricing Disputes: Conflicts arising from transactions between related entities in different tax jurisdictions.
• Employment Tax Disputes: Disputes involving payroll taxes, unemployment compensation, and worker's compensation.
• Sales Tax Disputes: Challenges to the application or collection of sales taxes.

Successfully resolving tax controversies requires a deep understanding of tax law, IRS procedures, and litigation strategies. Our legal team is dedicated to providing aggressive and effective representation to protect your financial interests and minimize your tax liabilities. Contact us today to discuss your specific situation.