Freeman Tax Law tax lawyers routinely litigate in both the US Tax Court and Federal District Courts in both Civil and Criminal Matters. These cases often begin at the Audit phase and expand through the IRS Administrative Appeals process until they ultimately wind up in the courtroom. We have significant experience in both written and oral advocacy for our clients at all these levels.
At the audit phase of a tax dispute, our involvement with the IRS can range from minimal to extensive, depending on the circumstances. We have broad experience in “behind-the-scenes” assistance in strategizing and responding to audit information requests in a way that best reflects the merits of the taxpayer’s return position and that preserves the attorney-client, work product and other applicable privileges. We also have extensive experience with special procedures, such as summons enforcement proceedings, requests for technical advice, closing agreements, fast track and accelerated issue resolution. As needed, we interact with the IRS revenue agents and field specialists, including ISP specialists, engineers, employee benefits specialists and international specialists.
At the administrative appeals phase of a tax dispute, we are actively involved in the oral and written advocacy of the client’s position, and we typically lead the negotiations with the IRS Appeals Officer and Technical Guidance Coordinator to determine whether the dispute can be favorably resolved without litigation.
If the dispute cannot be resolved administratively, we strategize with the client on the best choice of forum for litigating the tax dispute, taking into account the payment of tax, trial location, judges, government attorneys, timing and nature of the trial, settlement authority, publicity of proceedings, evidentiary rules, procedural rules, appellate jurisdiction and judicial precedent. We have litigated cases in the U.S. Tax Court, the U.S. Court of Federal Claims, district courts and appellate courts around the country. We also have successfully settled or mediated cases after they were docketed for litigation.
We have significant expertise with cases of first impression, cases involving complex transactions. Our practice was built in handling criminal matters involving tax evasion, complex collection matters, and international tax issues involving bank secrecy and FBAR violations for our clients. We are always up for a challenge and welcome the difficult or complex situation.
Contact us today for a consultation.