Whether you are facing a tax audit, appeal, or possible litigation, we can help. Getting a notice from the IRS is understandably scary, especially if you haven’t received one before. We work to expeditiously resolve matters while also being honest with clients about options and potential outcomes. We work with a multitude of other professionals, as needed, to ensure matters are addressed from every applicable angle.
Tax Planning
What is a Tax
Controversy?
Tax controversies can arise for many different reasons: a misunderstanding on a return, an issue flagged by a computer‑matching program, a question about a deduction, or something as simple as a missing form. Sometimes the issue is small and easily addressed. Other times, the IRS or state taxing authority believes a more significant adjustment is required. Regardless of the situation, responding promptly and strategically is critical. Many taxpayers unintentionally make matters worse by ignoring notices, responding incorrectly, or providing too much or too little information. We help clients avoid these pitfalls by guiding them through every step with clarity and precision.
The Lifecycle
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Most tax controversies begin with an audit or examination. This can be a correspondence audit conducted entirely by mail, an office audit requiring you to meet with an IRS representative, or a field audit conducted at your home or business. Each type has different procedures, expectations, and risks. We help clients understand what the government is asking for, why they are asking for it, and how to provide the appropriate information without oversharing or creating unnecessary complications. Our priority is to protect your rights, minimize exposure, and ensure the audit stays focused and properly managed.
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If an audit results in a proposed assessment, the next step is often an administrative appeal. Appeals are an opportunity to resolve disagreements without litigation. At the Federal level, they are handled by an independent branch of the IRS. This Independent Office of Appeals is tasked specifically with settling cases based on the hazards of litigation. This is often where strong legal advocacy can make a significant difference. We prepare persuasive submissions, negotiate with appeals officers, and develop a strategy at this important stage. Our goal is to communicate in a way that reflects both the legal strengths of your position and the practical realities of the case.
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In some situations, litigation becomes necessary to protect your interests. Most controversies never reach this stage. But if it does, we help clients evaluate when it makes sense to pursue litigation and what potential outcomes may look like. We also coordinate with tax litigators, accountants, valuation experts, and other professionals to ensure the case is thoroughly and strategically prepared. Our role is to make sure you understand the risks, opportunities, and likely paths forward so you can make informed decisions.
We also help clients evaluate and choose between different tax positions, such as whether to elect S‑corporation treatment for an LLC or how to structure partner compensation in a multi‑member business. These decisions can have long‑term effects on tax liability, profitability, and compliance. We work closely with clients to weigh the benefits and risks.
For individuals, tax planning often overlaps with a number of other facets of life. These include investment strategy, real estate decisions, retirement planning, estate and gift considerations, and the tax implications of significant life events. We help clients understand how major transactions — sales of assets, investment gains, inheritance, or charitable giving — will impact their tax picture.
Another key part of tax planning is preparing for major business events. When a business is being bought or sold, when owners are entering or leaving, or when the company is restructuring, tax consequences are often one of the most critical elements of the transaction. Thoughtful planning at the beginning can prevent unpleasant surprises later.
We also assist clients in understanding multi‑state tax issues. This is becoming more and more relevant as more businesses expand across state lines or operate online. Different states have different rules regarding income sourcing, sales tax, nexus, and reporting requirements. We help clients navigate think through these issues and connect with appropriate resources to ensure compliance.
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Tax controversies also frequently involve penalties, interest, collection actions, or questions about payment options. We assist clients with penalty abatement requests, installment agreements, offers in compromise, and other mechanisms available for managing tax liabilities. For clients facing aggressive collection actions—such as liens, levies, or wage garnishments—we act quickly to protect assets, stop harmful enforcement actions, and find a workable resolution.
Throughout the entire process, communication is key. Taxpayers often feel overwhelmed not because the issue is unsalvageable, but because they don’t know what the IRS is really asking or what their rights are. We take the time to explain the process, outline realistic expectations, and ensure clients feel supported and informed from start to finish. Every case is different, but every client deserves a clear plan, honest guidance, and a strong advocate.
WHY IT MATTERS
Ultimately, our approach to tax controversy work is grounded in practicality and protection. We aim to resolve matters as efficiently as possible while safeguarding your rights and minimizing long‑term impact. Whether your issue is small or significant, we are here to help you navigate it with confidence and clarity.