Civil and Criminal Tax Controversies
Represent clients before the Internal Revenue Service and state taxing authorities at the audit and appellate levels, in all levels of federal and state courts, responding to challenges by tax authorities, possessing familiarity with agency practices and methods.
Resolve issues in a quick and successful manner, looking for innovative ways to settle tax controversies before litigation, but ready to go to court when that is beneficial to the client. Experienced in all areas of negotiation with tax agencies, and all phases of tax litigation including responding to audits, summonses and subpoenas; preparing protests, petitions, discovery, trials and appeals. Represent clients accused of failing to report income, overstating deductions, failing to collect and pay over employment taxes, preparing false returns, failing to file returns, and other tax-related actions. Aggressive representation of individual clients in federal and state investigations, enforcement proceedings, and civil and criminal forfeiture.
Federal Income Tax
Handle federal income tax matters of corporations, partnerships, individuals, estates and trusts. Represent taxpayers before the Examination Division, Appeals Office and Collection Division of the IRS, the United States Tax Court and in the United States District Court. Obtain relief through abatements of penalties, acceptances of offers in compromise, and innocent spouse rules.