Rulings, Audits and Litigation

The outcome of an IRS or state tax audit often turns on applying complex legal principles to your facts.  Knowledgeable, effectively communicated legal analysis can make the difference between paying through the nose or smelling like a rose.

  • Advance Rulings: There are times when your peace of mind requires a prior ruling from the IRS or other tax authority before the transaction closes, thus avoiding a controversy before it even starts.
  • Audit Protests: After an auditor reaches his or her conclusions on liability, your first appeal is to an internal supervisor. The auditor’s weakest arguments are weeded out here.
  • Post-Audit Appeals: Once an audit report is final, you can get a fresh review from an independent appeals officer. This is the first level at which the IRS will consider “hazards of litigation,” that is, whether the taxpayer’s arguments are good enough to win in court.
  • Tax Court: A case may be so complex, contentious, or high-value that it ends up in Tax Court. Specialized judges with deep tax expertise will hear your case and render a verdict. Professionalism and top-notch legal advocacy are a must.
  • Collaborative Approach: Managing your tax controversy in the most competent, cost-effective manner requires collaboration among the tax lawyer, accountant, appraisers and valuation consultants, litigation specialists, and other professionals.