Tax Disputes

Resolving a dispute with the IRS (or a State taxing authority) can be a frustrating and costly experience. You need someone on your side who has both substantive tax knowledge and a thorough understanding of the procedural rules governing the various forums where tax disputes are heard.

Litigation experience is only a small part of knowing how to resolve a tax dispute. Because the vast majority of tax controversies are handled and resolved at the administrative level, you need a representative with the experience and judgment to know when a dispute should be settled, and when a dispute should be tried.

While some tax audits may seem benign, it is important to remember that, notwithstanding claims of “customer service” to the contrary, the IRS’s primary function is revenue collection, and statements you make to an IRS agent today might be used against you several years from now. Similarly, documents you or your accountants provide to the IRS in response to an “informal” request might contain information that leads to an expansion of the agent’s examination.

We have substantial experience litigating tax cases in the U.S. Tax Court, the U.S. Court of Federal Claims, the U.S. Bankruptcy Court, and a number of district courts around the country. We have also resolved innumerable tax disputes informally, at the Exam and Appeals levels. Because we have an office in Washington, D.C., we have access to top personnel at the IRS and the Tax Division of the Department of Justice and can alert clients to new IRS programs like the Offshore Voluntary Compliance Initiative. We work with our clients to assess not just what the correct outcome of a dispute is from a tax perspective, but what the best outcome is from the client’s personal or business perspective. Put another way, we never forget that spending two dollars to recover one is not in your best interest.