Tax Representation Controversy
Tax Representation Controversy our professionals have extensive experience helping our clients defend against tax adjustments and penalty and interest assessments as well as navigate IRS negotiations. We leverage our in-house technical expertise to help businesses and individuals understand potential examination issues, proactively alerting our clients to areas of focus from both the IRS and state tax authorities.
Your needs may occasionally go deeper. If you face especially thorny tax issues, we can also research complex tax matters and provide detailed legal analysis to help with return preparation and other requirements.
The sums you could save are significant: We’ve helped hundreds of clients settle IRS disputes for less than what was initially assessed and in many cases, we were able to completely eliminate any penalties, resulting in no tax due.
How We Serve You
- Examinations We can help manage the process, including limiting document requests, using legal authority to narrow the scope of audits, and mediating to resolve audits quickly and efficiently.
- Appeals Tax, penalty, and interest assessments are becoming much harder to resolve administratively. We can provide representation to expedite resolution and help reduce your tax exposure.
- Penalty Abatement Whether the issue involves filing returns late, paying late, or failing to file required information returns, we can help get penalties abated.
- Collection matters The IRS is increasingly employing its enforcement tools to collect unpaid tax and penalties. We can help determine if the underlying liability is valid, explore administrative remedies, and help remove liens and prevent levies.
- Private-letter rulings You can use a PLR to obtain an administrative ruling on a particular tax position. They’re also useful for obtaining late election relief. We can draft the PLR and guide it through the submission process.
- Taxpayer Advocate requests We can engage the Taxpayer Advocate Service on your behalf to help resolve procedural issues with the IRS, such as refund delays or denials or correcting erroneous records.
- Proactive planning We can identify and help mitigate issues before they become disputes, including areas specific to pass-through entities, passive activity losses, foreign reporting requirements, and substantiation of high-scrutiny business deductions and accountable plans.
State tax disputes are fairly common and arise throughout the tax spectrum, from income and franchise tax to sales and use tax and from employment tax to property tax. Yet how a dispute is handled can often mean the difference between a sizable tax bill and a sizable tax refund.
We can help you discern your tax risks and exposures—and effectively manage your state audits and tax disputes. Our state and local tax professionals combine deep technical knowledge, strong relationships with government officials, and tax resolution experience to help you expedite and successfully resolve time-consuming disputes.
Our team contains a number of former state government officials who can readily determine audit issues under exam, areas of concern, and refund opportunities that state auditors don’t want taxpayers to raise during the examination. Even if your audit has been completed, we can still help via the state’s administrative dispute process to resolve such exams with significantly less taxes due or none at all. We have a track record of saving our clients millions of dollars each year managing audits and negotiating favorable settlements.
How We Serve You
- Tax refund reviews Instead of searching for potential assessments, our team finds and recover state income tax, indirect tax, property tax, and local tax refunds. We represent you from the filing of the refund claim through receipt or application of the refunds.
- Tax dispute prevention We know the exposure areas and can help you develop sound policies and processes to help safeguard your organization against future audits and disputes.
- Tax dispute resolution We strategically and cooperatively work with state tax jurisdictions to defend you and your business against proposed tax, penalty, and interest adjustments and, if needed, negotiate with state and local taxing authorities to favorably resolve your tax dispute.
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