Tax Controversy & LitigationA dispute with the IRS can be one of the most frustrating and emotionally draining events an individual or business can face. The Internal Revenue Code is complicated, and the procedures for contesting tax and penalty assessments are filled with critical deadlines and other potential pitfalls that could prejudice a taxpayer’s rights if a controversy is not properly handled. Many taxpayers decide to handle a tax controversy on their own, only to find themselves in over their heads, or worse, procedurally barred from disputing a tax or penalty.
Our attorneys have experience representing individuals and business owners in all aspects of tax controversies, from the initial audit or assessment, to protests and appeals, to litigation with the IRS or Department of Justice. Regardless of what phase a client’s tax controversy is at when our attorneys are engaged, they can help navigate the client through the tax controversy process and obtain the best possible result given each client’s situation.
Our attorneys also have experience representing tax preparers and accountants in actions by the IRS, DOJ and Office of Professional Responsibility seeking preparer penalties or sanctions. Such matters can involve substantial monetary penalties or even revocation of a tax preparer’s or accountant’s right to earn a living by preparing tax returns or providing tax related services. Because the stakes are often high in such matters, it is best to seek professional counsel experienced in such cases.