Tax Controversy
The Internal Revenue Service, the State Department of Revenue, as well as other taxing authorities, cause problems. Although most of the employees at these agencies are diligent, hard-working, honest people, some display behaviors that run afoul of the rights of individuals and businesses.
We handle all tax controversy matters. In these, we:
- Identify issue(s) pre- or during the audit,
- Defend the audit in conjunction with top-tier C.P.A.s, including defending summons enforcement and the like
- Appeal of the Examiner’s decision to the Office of Appeals
- Litigate the matter before the United States Tax Court
- Appeal of the decision of the United States Tax Court and
- Defend the collection actions of the IRS after assessment.
Criminal tax matters have their own, unique path. In criminal tax matters, we handle the issues listed above, but also:
- Respond to summons and the defense of summons enforcement
- Respond to the execution of search warrants and seek recovery of the materials taken
- Conduct our own investigation of the issues, interview witnesses, and prepare for defending the matter on the merits
- Petition the United States Department of Justice before a decision is made on charging
- Defend the client in the trial of the criminal tax matter on the merits to a verdict
- And, if necessary, appeal of the trial court outcome to the United States Court of Appeals.