The Tax Court is the only judicial forum (other than the bankruptcy courts) that allows a taxpayer to litigate a liability for income, estate, or gift tax before paying the amount in dispute. We file petitions with the U.S. Tax Court, challenging the IRS audit determinations on a regular basis. We handle discovery and prepare the case for trial while attempting to reach a favorable settlement for our clients. If settlement cannot be reached, you will be represented by a trial attorney with over 20 years’ experience before the U.S. Tax Court.
Prior to filing a tax case in United States District Court, a taxpayer is required to pay the disputed amount, request a refund of the disputed amount from the IRS, receive a denial of the refund request from the IRS, and exhaust all IRS administrative remedies. After all of the procedural prerequisites have been met, the taxpayer can file a suit for refund in District Court. Although most people don’t choose to go this route, we are fully qualified to successfully represent you in District Court.
Should a judgment be held against you in Tax Court or District Court, you have the option to appeal the court’s findings to the U.S. Appeals Court if you decide to appeal, we will file the appeal for you. We will present oral argument to a 3 person panel of judges advocating your position and defending your rights.
If IRS has not followed all the rules, an IRS settlement officer has the authority to reverse the decision made by a collection agent. A collection due process hearing may be just the solution you need to reduce your tax liability. Our experts have over 20 years’ experience handling collection due process hearings and getting excellent results.
You have rights when a tax lien has been filed against your property. We can request a Collection Due Process Hearing and advocate your position before an IRS settlement officer. If the officer rules against you, we can file a petition with the U.S. Tax Court and ligate the issue for you.
We examine the facts of your case to determine how best to bring you into compliance with U.S. tax laws and avoid the potential of criminal sanctions. Recommended options may include: (1) a special OVDI disclosure when the failure to report is willful, (2) a streamlined program when the failure to disclose is non-willful, or (3) a late submission. We will bring you up to date with a special Foreign Bank Account Reporting (FBAR) and FATCA requirements and negotiate with the IRS to keep the potential penalties to a minimum.