Tax Controversy

The Internal Revenue Service, the state Department of Revenue, as well as other taxing authorities, cause problems.  Although most of the employees of 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 we:

  • 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, only if necessary, sentencing) and
  • Appeal of the trial court outcome to the United States Court of Appeals.