General Corporate Law

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.

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