Federal Tax Controversy & Dispute Resolution
The IRS is authorized to make tax assessments, levy fines, and issue penalties, but that doesn’t mean it’s always right. Whether you’re facing an IRS audit or trying to head one off, we can help you resolve tax disputes, controversies, and other procedural matters.
Our tax professionals have extensive experience helping our clients defend against tax adjustments and penalty and interest assessments as well as navigate IRS negotiations. We leverage our in-house technical expertise to help businesses and individuals understand potential examination issues, proactively alerting our clients to areas of focus from both the IRS and state tax authorities.
Your needs may occasionally go deeper. If you face especially thorny tax issues, we can also research complex tax matters and provide detailed legal analysis to help with return preparation and other requirements.
The sums you could save are significant: We’ve helped hundreds of clients settle IRS disputes for less than what was initially assessed and in many cases, we were able to completely eliminate any penalties, resulting in no tax due.
State & Local Tax Controversy & Dispute Resolution
As state and local tax jurisdictions continue to increase enforcement of tax laws and regulations, being prepared for a potential audit—and the subsequent protest, appeals, and settlement processes it can entail—helps you secure the resolution you want. We can provide guidance and representation that protects your interests at every step of the process, from the audit to a potential settlement or appeals process.
How We Serve You
- Examinations. We can help manage the process, including limiting document requests, using legal authority to narrow the scope of audits, and mediating to resolve audits quickly and efficiently.
- Appeals. Tax, penalty, and interest assessments are becoming much harder to resolve administratively. We can provide representation to expedite resolution and help reduce your tax exposure.
- Penalty abatement. Whether the issue involves filing returns late, paying late, or failing to file required information returns, we can help get penalties abated.
- Collection matters. The IRS is increasingly employing its enforcement tools to collect unpaid tax and penalties. We can help determine if the underlying liability is valid, explore administrative remedies, and help remove liens and prevent levies.
- Private-letter rulings. You can use a PLR to obtain an administrative ruling on a particular tax position. They’re also useful for obtaining late election relief. We can draft the PLR and guide it through the submission process.
- Taxpayer Advocate requests. We can engage the Taxpayer Advocate Service on your behalf to help resolve procedural issues with the IRS, such as refund delays or denials or correcting erroneous records.
- Proactive planning. We can identify and help mitigate issues before they become disputes, including areas specific to pass-through entities, passive activity losses, foreign reporting requirements, and substantiation of high-scrutiny business deductions and accountable plans.