Tax Controversy
Hone Maxwell LLP’s unique experience in public accounting and tax preparation means the team has a comprehensive understanding of every tax situation and problem – including tax controversy matters. HMLLP’s Tax Controversy practice includes tax attorneys with experience advising and representing clients before federal, state and local taxing authorities and in all federal and state courts where tax disputes are litigated. HMLLP’s Tax Controversy practice provides support and zealous advocacy for individuals and businesses that disagree with taxing authorities’ assessments.
Disagreements with the IRS over tax return examination results or other tax liability adjustments can be appealed to an IRS Appeals Office. It is critical that appeal requests be submitted before the deadline and in the proper form. Advanced preparation before discussing and arguing disputed issues with an appeals officer is key to the success of a tax appeal. When matters are resolved at this stage the risk of incurring additional legal fees is reduced. Working with an experienced IRS lawyer, like the HMLLP tax attorneys, is recommended for fast and efficient tax appeals resolutions.
If a tax controversy can’t be resolved through the appeals process, the matter can be elevated to the United States Tax Court. Only tax attorneys admitted to practice before the Tax Court may argue before this court on behalf of clients. Taxpayers should not underestimate the importance of hiring a tax attorney who understands the Tax Court’s unique procedures and requirements and the nuanced tax procedure and controversy process.
When Tax Court is not available, there is always the option to use the standard court procedures and file in U.S. District Court to litigate tax controversy matters. While this is not a common practice, in the right situation it can be an excellent option.
HMLLP tax attorneys have extensive experience resolving tax controversy issues for individuals and businesses, providing cost-effective counsel that yields excellent outcomes.
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Tax controversy law involves resolving disputes between taxpayers and taxing authorities such as the IRS or state tax agencies. Common matters include audits, tax assessments, penalties, appeals, collections, tax liens, levies, and tax litigation.
You should contact a tax controversy attorney as soon as you receive an IRS notice, audit letter, proposed assessment, levy notice, or other tax enforcement action. Early intervention often provides more options for resolving the matter.
Yes. A tax controversy attorney can communicate directly with the IRS, respond to information requests, develop legal arguments, and help protect your interests throughout the audit process.
A Notice of Deficiency is a formal notice that gives you the opportunity to challenge a proposed tax assessment. Because strict deadlines apply, you should consult a tax controversy attorney immediately to evaluate your options.
In many cases, penalty relief may be available through reasonable cause arguments, administrative appeals, or other IRS procedures. The best approach depends on the facts and circumstances of the case.
The IRS offers several collection alternatives, including installment agreements, offers in compromise, and other resolution programs. A tax controversy attorney can help determine which option is most appropriate for your situation.
Yes. Tax controversy attorneys regularly assist clients with IRS collection actions, including tax liens, bank levies, wage garnishments, and other enforcement measures. Acting quickly can help prevent additional financial consequences.