We specialize in complex IRS tax litigation in civil and criminal tax. 

Our IRS tax litigation experience includes:

• IRS Substitute for Return procedures
• IRS Notice of Deficiency procedures
• IRS Failure to File procedures
• IRS Audit Reconsideration procedures
• IRS Appeal procedures
• IRS Assessment procedures
• IRS Collection procedures
• IRS Collection Due Process Hearing procedures
• IRS Collection Alternative procedures such as installment agreements and offers in compromise
• IRS Trust Fund Recovery Penalty procedures
• IRS Notice procedures
• IRS Lien and levy procedures
• IRS Seizure and Foreclosure procedures

We have IRS tax litigation experience in specialized areas including:

• Abusive domestic and foreign trust
• Partnerships, corporations, limited liability corporations
• Areas identified by IRS as “Tax Protestor Schemes”

IRS tax litigation can be extremely complex and overwhelming.  IRS tax litigation goes well beyond the preparation of a tax return.  Some questions of importance in identifying what your issues are and where your IRS tax litigation begins are:

• Have you received any notices from the IRS and what type of notice
• Have you filed all tax returns with the IRS
• Are you being investigated by the IRS Criminal Investigative Division
• Have you submitted any correspondence to the IRS and what kind
• Do you have any IRS civil penalties assessed against you
• Have you received any IRS Statutory Notices of Deficiency
• Have you had any IRS tax litigation in the past if so for what years
• What kind of IRS tax litigation have you had
• Have any of the IRS statutes of limitations run for assessment, collection and refund
• Have you submitted any offers in compromise and/or installment agreements to the IRS in the past and what were the results
• Have you participated in any known “Tax Protestor Schemes”
• Has IRS made any collections by levy
• Do you have a Notice of Federal Tax Lien filed against you by the IRS
• Have you filed bankruptcy, if so when
• Have you participated in any offshore activity
• Do you have any offshore bank accounts or foreign assets

These are only a few of the questions that help identify your IRS tax litigation issues.  We are experienced in complex tax litigation for civil and criminal tax and can help you understand what your issues are and how you can proceed.  Understanding and identifying options available to you is your first step to determine how to resolve your IRS tax litigation quickly and efficiently

Please call 1-800-447-6181 for a free consultation.