Unfiled Tax Returns
The IRS considers failure to file your tax returns a serious violation. It's best to address the issue before the IRS finds you. We can help you make a voluntary disclosure to minimize your risk of criminal prosecution and reenter the voluntary compliance system.
If none of the options above are available, your last resort is to pay the tax due and then seek a refund. We will help you prepare a refund claim and work with the IRS to persuade them to accept the claim as filed. If they don't, we will file a refund suit in the United States Court of Federal Claims or the United States District Court.
If the Appeals Officer won't agree to an acceptable settlement. we will file a petition in the United States Tax Court for determination by an independent judge. We will try to negotiate a reasonable settlement with the opposing attorney but if we cannot, we will try the case in court.
When the normal avenues are exhausted, the IRS will formally bill you for additional taxes and begin trying to collect. If you come to us at this stage, the options above may not be available but we will help you protect your "collection due process" rights before the IRS garnishes your wages or levies against your property. If possible, we will challenge whether you owe the additional tax or penalties. Even if that is not possible, we will help you with alternatives, such as an installment plan or an offer in compromise.
During an audit
We will help you understand what the auditor is asking for, and why. We will help you provide information clearly and in the best way to persuade the IRS that your position is correct, without raising new concerns. We will provide the legal arguments necessary to support your position and negotiate with the auditor to avoid any adjustments.
Internal Administrative Appeals
If you don't like the result you got from the audit, we will resolve the problem with the IRS's internal administrative appeals function. We will prepare a written protest setting forth the facts and legal arguments in support of your position, and we will work with the Appeals Officer to reach the best solution possible for you.
We provide services for all stages of tax disputes. We will always clearly explain what's going on with your situation, what options you have, and the pros and cons. We believe in your case and will zealously advocate for you when dealing with the IRS, but we will also always give you an honest and objective evaluation of the strength of your position. We understand tax law, the complex process required to resolve disputes, and your rights. With our help, you'll be able to confidently choose the strategy and approach that's best for your situation.