Practice Subgroup

Audit appeal and defense

No one enjoys being audited, but a taxpayer should not back down and give up. Our attorneys know the tax laws, and we are on our clients' side. We present the facts in the best light to achieve the best results -whether it is convincing the IRS to allow a deduction or demonstrating whether a transaction generates taxable income.

We are not intimidated by IRS agents, who must follow applicable procedures. We will have a case transferred to the agent's manager or to IRS Appeals if the agent takes unreasonable positions or acts unprofessionally. The job of IRS Appeals is to mediate cases. Because we have experience litigating matters in Tax Court, the IRS knows that we will not give up, which frequently allows us to obtain a favorable settlement of a tax matter. We do what's right for the people we represent.

We also work with our clients in structuring installment agreements, making offers in compromise, collection due process hearings, and defending against IRS summonses. Our attorneys have had success for clients in obtaining innocent spouse relief, fighting the 100 percent responsible person liability, and transferee liability.