Tax Controversy & IRS Defense

Experienced Advocacy When Tax Disputes Arise

Facing an IRS audit or state tax controversy can be overwhelming and disruptive to your business or personal life. Our tax controversy team provides skilled representation and strategic advocacy to resolve disputes efficiently while protecting your interests and minimizing exposure.

IRS Examination Defense

When the IRS selects your return for examination, experienced representation is crucial:

  • Audit Representation: Handling correspondence, office, and field audits
  • Document Production: Strategic response to information requests
  • Issue Development: Working with revenue agents to clarify and resolve questions
  • Negotiation & Settlement: Achieving favorable resolutions when possible

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State Tax Controversy

State tax disputes often involve complex multi-jurisdictional issues:

  • Income Tax Audits: Defending state income tax examinations
  • Sales Tax Disputes: Addressing use tax, nexus, and exemption issues
  • Nexus Challenges: Defending against claims of business presence
  • Voluntary Disclosure: Proactively resolving compliance issues
  • Administrative Appeals: Challenging adverse state determinations

When tax liabilities cannot be paid in full, we help explore options:

  • Installment Agreements: Negotiating manageable payment plans
  • Offers in Compromise: Settling tax debts for less than full amount
  • Currently Not Collectible Status: Obtaining temporary collection relief
  • Innocent Spouse Relief: Protecting spouses from joint return liability
  • Collection Due Process Hearings: Challenging collection actions

We currently only represent clients at the following levels of IRS dispute resolution:

  • IRS Appeals Office: Independent review of examination and collection issues
  • Settlement Negotiations: Achieving resolution without formal litigation

The best defense is often avoiding controversies before they start:

  • Compliance Reviews: Identifying and addressing potential issues
  • Documentation Strategies: Maintaining records that support tax positions
  • Voluntary Disclosures: Correcting past errors on favorable terms
  • Penalty Protection: Implementing procedures to avoid common penalties

Business tax disputes often involve high stakes and complex facts:

  • Corporate Tax Examinations: Defending business deductions and credits
  • Partnership Audits: Navigating centralized partnership audit rules
  • State Apportionment Disputes: Multi-state income allocation issues
  • Industry-Specific Issues: Specialized knowledge for particular sectors

Why Choose Our Controversy Team

Strategic Thinking

Focus on achieving best overall outcomes

Efficient Resolution

Minimizing time and costs while protecting interests

Technical Expertise

Deep knowledge of tax law and procedure

Client Communication

Regular updates and clear explanations throughout

Early Intervention Advantage

The earlier we become involved, the better we can protect your interests. Whether you’ve received an audit notice, collection letter, or are concerned about potential issues, prompt action often leads to better outcomes.
Don’t face the IRS or state tax authorities alone. Our experienced controversy team provides the advocacy and expertise you need to resolve tax disputes effectively and minimize their impact on your business or personal finances.

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