TAX CONTROVERSY, LITIGATION AND COLLECTION MATTERS
When the government has questions, our tax attorneys have answers. Our attorneys have the knowledge and experience to defend clients in any type of tax controversy. We have extensive experience representing businesses and individual clients during audits and other controversy matters before the IRS, state and other local taxing jurisdictions.
We serve as trusted advisors to our clients on all types of tax matters. Our attorneys have impressive qualifications, including holding Masters of Law (LL.M.) degrees in Taxation, being licensed Certified Public Accountants, holding Board Certifications, and/or having held positions within various collection agencies or serving on related boards and committees.
The clients we represent in audits or tax controversy are quite diverse, and can range from an individual taxpayer or small business owner to a large publicly traded company. A client’s tax dispute with the IRS, state or local taxing authority can present unique and complex challenges. No two clients are the same. Our attorneys pride themselves in reaching the best result for clients under the specific circumstances of each case.
Pre-controversy tax advice: Our tax advice and planning considers potential challenges by the IRS to ensure that our client’s tax reporting position can be sustained on IRS examination. Our tax litigation experience has shown that tax cases are often won or lost based on the client’s actions or inactions at the time that transactions are consummated and reported. We counsel clients on document retention, tax department management, and privilege issues. We have helped many clients gain certainty as to their tax position by obtaining private letter rulings and determinations from the IRS on various tax issues.
IRS Audits and IRS Examinations: We are actively involved in every aspect of the IRS examination process with the goal of obtaining a favorable outcome for our clients in the most cost effective means possible. We counsel clients on strategies for responding to information document requests, meeting with IRS representatives, negotiating settlements with the IRS, pre-filing agreements, technical advice, Fast Track Appeals resolution, Statute of Limitations, IRS summons, and Closing Agreements.
IRS Appeals: If our clients are not satisfied with the results of an IRS examination, we are thoroughly experienced in the strategies and procedures related to protesting cases in the IRS Appeals Office, including negotiating with IRS Appeals Officers, and settling tax issues prior to litigation.
Working with Certified Public Accountants: We routinely assist CPAs with IRS audit advice or support. We can provide support to CPAs in various ways from taking the lead in IRS examinations to providing legal analysis of discrete issues.
We are also regularly involved in Louisiana audit defense, and tax litigation at the state and local level. We routinely appear on behalf of clients before Louisiana administrative boards, such as the Louisiana Board of Tax Appeals and Louisiana Tax Commission.
Best Forum to Litigate a Tax Case: When litigation of a tax issue is appropriate and required to resolve a tax issue, clients can rely on our attorneys to identify the benefits and risks of particular forums in which to litigate the tax case. We have represented clients before the U.S. Tax Court, U.S. Federal District Courts, and U.S. Court of Federal Claims. As noted above, we also have experience in state and local tax matters and have represented clients in all state tax forums including the Louisiana Supreme Court.
Trial Experience in Tax Cases: Our approach takes into account the needs of each client, utilizing strategies that offer the best opportunities for success while managing the litigation process to provide value and efficiency for the client. Our trial attorneys are known for advocacy, judgment, and responsiveness. Listening, understanding and believing in the goals of our clients are our guideposts in delivering results at the courthouse.
Tax Collection Matters
Our attorneys handle all forms of tax collection matters. Our attorneys are often called upon by our individual and business clients, as well as other attorneys and CPAs, to provide their knowledge and insight into the IRS, state or local tax collection process. We provide our clients with candid and accurate advice on their legal rights and their potential for:
offers in compromise,
innocent spouse claims, and
other permissible defenses tax collection measures.
Our attorneys are here to help you resolve your tax collection problem and protect your legal rights. We pride ourselves on being efficient, effective, and of course discrete in all client tax collection matters.