Tax Controversy & IRS Representation

Skilled advocacy for individuals and families facing IRS audits, tax disputes, penalties, and collection actions — protecting your rights at every stage of the administrative and judicial process.

"Early intervention is one of the most important factors in a successful tax controversy outcome. The longer an examination or dispute is handled without qualified legal counsel, the narrower your options become."

Services Include

  • IRS Audit & Examination Defense

  • Estate & Gift Tax Dispute

  • IRS Appeals Representation

  • U.S. Tax Court Litigation

  • FBAR Penalty Defense

  • Collection Defense & Negotiation

  • Offers in Compromise

  • Penalty Abatement

  • Innocent Spouse Relief

  • Lien & Levy Resolution

Frequently Asked Questions

  • Contact a tax attorney before responding. The IRS audit process is formal and adversarial — statements made during an examination can be used against you. An attorney can review the notice, assess the scope of the examination, advise you on your rights, and handle all communications with the IRS on your behalf.

  • Yes. Most taxpayers can request an Appeals conference after receiving a Revenue Agent's Report (RAR) proposing adjustments, without paying the tax or filing a petition in Tax Court. IRS Appeals offers a valuable opportunity to resolve disputes before litigation, and many cases settle favorably at the Appeals stage.

  • An Offer in Compromise (OIC) is an agreement between a taxpayer and the IRS that settles a tax liability for less than the full amount owed. The IRS will consider an OIC when there is doubt as to collectibility, doubt as to liability, or when payment in full would create an economic hardship. Not all taxpayers qualify, and the process requires careful preparation.

  • Estate tax audits often focus on asset valuations — particularly closely held business interests, real estate, and minority interest discounts — as well as deductions for debts and expenses. They frequently involve competing appraisals and expert testimony. Our attorneys have specific experience representing estates through IRS examination and appeal of estate tax deficiencies.

Facing an IRS Matter?

Don't navigate a tax dispute alone. Our attorneys provide strategic representation from day one.

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Schedule a Consultation

Experienced Advocacy When It Matters Most

Receiving an IRS notice or audit letter is stressful — and responding incorrectly can significantly worsen your position. Whether you are facing an income tax audit, an estate tax examination, a foreign account penalty, or an aggressive IRS collections action, having skilled legal representation from the outset is critical.

Our tax controversy attorneys bring a deep understanding of IRS procedures, substantive tax law, and negotiation strategy. We represent clients at every stage of the administrative process — from initial examination through IRS Appeals — and in the U.S. Tax Court and federal courts when litigation is necessary.

Areas of Representation

Our tax controversy practice encompasses a broad range of matters, including:

  • IRS income tax audits and examinations (individual, partnership, and trust)

  • Estate and gift tax audits and valuation disputes

  • Foreign account and international reporting penalty disputes

  • FBAR civil penalty defense

  • IRS Appeals representation

  • U.S. Tax Court litigation

  • Federal district court and Court of Federal Claims litigation

  • Innocent spouse claims

  • IRS collection defense — liens, levies, installment agreements, offers in compromise

  • Penalty abatement requests

  • Criminal tax referral defense (in coordination with criminal defense counsel)

The Tax Controversy Process

Most tax disputes begin with an IRS examination — either a correspondence audit (conducted by mail) or a field or office audit (conducted in person). The examination concludes with a revenue agent's report proposing adjustments. From there, taxpayers have the right to:

  • Protest the proposed adjustments to IRS Appeals

  • Participate in Fast Track Settlement or Mediation

  • File a petition in the U.S. Tax Court before paying the disputed tax

  • Pay the tax and file a refund claim in federal district court or the Court of Federal Claims

We analyze each client's facts, the merits of the IRS's position, and the available procedural options to build the most effective strategy for resolution.

IRS Collections Defense

When a tax liability has been assessed and the IRS moves to collect, taxpayers face an escalating series of notices, liens, and potential levies on wages, bank accounts, and property. Our attorneys represent clients in:

  • Collection Due Process (CDP) hearings

  • Installment agreement negotiations

  • Offers in Compromise

  • Currently Not Collectible status requests

  • Lien subordination, withdrawal, and discharge

  • Levy releases