We represent clients before the Internal Revenue Service (IRS) Audit/Examination Division and IRS Appeals Office and have been involved in matters at all levels of the federal court system, including the US Tax Court, the US Court of Federal Claims, US district courts, and US Courts of Appeal.

 

The majority of our cases are resolved administratively without going to trial. But sometimes tax court litigation is necessary to protect our clients’ interests. We have experience settling tax disputes through alternative dispute resolution procedures, including Fast Track Settlement and Post-Appeals Mediation, and in representing clients in Compliance Assurance Process (CAP) audits. We represent taxpayers who are facing civil and criminal issues regarding their reporting of offshore financial accounts and other assets.

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Our attorneys have proven skills and experience in all aspects of tax

controversy including:

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•  IRS Collections, Liens and Levies and Collection Due Process suits

•  Managing and settling IRS audits/examinations

•  Preparing and filing written protests to IRS Appeals

•  Negotiating with the IRS Appeals Officer

•  Preparing and Trying cases in tax court

•  IRS Summons Defense

•  Payroll Tax Collections  

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Our controversy docket keeps us update to date of the evolving administrative and judicial practice and procedures, strategy, and tactics.   

 

White-collar criminal experience.  We have experience in white-collar tax criminal cases involving high profile individuals.