Tax Audits and Administrative Appeals
We are a tax controversy firm comprised of tax controversy lawyers specializing in tax controversy matters.
We maintain an active practice representing individuals, large and closely-held entities, partnerships, estates and others in administrative tax disputes and controversies with all taxing authorities. Our tax controversy lawyers have successfully represented clients in all levels of Federal and State administrative tax disputes, including representation before the Examination Division and Appeals Office of the Internal Revenue Service. We also represent taxpayers with respect to income tax and residency audits and appeals conducted by the California Franchise Tax Board (FTB), sales and use tax audits by the California State Board of Equalization (BOE) and employment tax audits by the Employment Development Department (EDD).
We strive to resolve cases as early in the process as possible and work with the clients to find innovative solutions to often sensitive or seemingly difficult or impossible tax-related problems. We routinely assist clients and their other tax advisors in managing and developing a meaningful audit strategy, interfacing with the examining Revenue Agent, coordinating efficient and effective responses to government requests for information [including Information Document Requests (IDRs) and Summonses], large document production, informal and formal interviews and depositions and aggressively pursuing Freedom of Information Act (FOIA) requests for information contained within the government’s administrative files, etc.
We have the resources, knowledge and substantive tax expertise to successfully represent taxpayers involved in a wide array of unresolved tax disputes with federal and state taxing authorities. We also have the depth of understanding necessary to effectively move through the various administrative levels of the IRS and state taxing authorities as well as negotiating with the Tax Divisions of the U.S. Department of Justice or local Offices of the U.S. Attorney.
We routinely represent and advise taxpayers involved in complex or sensitive issue civil tax examinations where substantial tax, civil penalty issues or possible assertions of fraudulent conduct may arise; voluntary disclosures of previously undisclosed interests in offshore financial accounts and assets through the ongoing IRS Offshore Voluntary Disclosure Program (OVDP), the IRS Streamlined Filing Compliance Procedures program or otherwise; voluntary disclosures involving purely domestic issues thereby both avoiding criminal prosecution and limiting civil penalty exposure; examinations involving “listed transactions” and other technical “tax shelter” transactions; examinations involving disputes over residency or source of income; taxpayers who have failed to timely file tax returns and in effectively defending criminal tax fraud administrative and Grand Jury investigations and prosecutions.
Recent examinations handled by our tax controversy lawyers include comprehensive income tax examinations by the IRS Global High Wealth Industry examination group; examinations involving offshore financial accounts and income; Foreign Bank Account Report (FBAR) penalty investigations and appeals; complex estate and gift tax audits involving high-profile individuals; employment tax audits by the IRS and EDD; income tax audits and California residency disputes by the FTB; estate and gift tax examinations and appeals; sales and use tax audits by the BOE; trust fund recovery penalty investigations by the IRS; responsible person investigations by BOE and EDD; worker classification issues; innocent spouse issues; TEFRA partnership audits; return preparer and tax shelter promoter penalty audits; tax shelter investigations and audits; and in defending accountants and other return preparers in government investigations.
Our tax controversy lawyers are equally comfortable being on the front lines of an examination as we are in providing advice and coordinating activities with other tax professionals from the bleachers. The degree, nature and extent of our representation depends on the unique needs of each client and their particular facts and circumstances.
If you are facing any inquiry or examination from the taxing authorities, we can help.