Federal Tax Controversies
Since 1985 we have represented clients in a great many Federal tax controversies. We represent clients in tax assessment cases as well as tax collection cases. We enjoy excellent working relationships with Internal Revenue Service personnel, and we obtain excellent results for clients from them.
In Federal tax assessment cases, we contest proposed assessments of taxes and penalties. We also seek abatement of taxes and penalties already assessed.
In Federal tax collection cases, we secure a hold on tax collection against the client. Then we obtain transcripts of the client’s pertinent Federal income tax accounts, and analyze them for income tax returns or amended income tax returns that need to be filed, or penalties for which we should seek abatement. If the client is unable to pay lawfully owing tax balances, we resolve the balances by means of a currently-non-collectible posting, an installment agreement, or an offer-in-compromise. When appropriate we refer a client to bankruptcy counsel, and work with the bankruptcy attorney in discharging the client’s tax balances in bankruptcy.
If we are unable to satisfactorily resolve a tax controversy at the revenue officer or revenue agent level, we take it to the Internal Revenue Service Appeals Office. We do some of our best work before the IRS Appeals Office.
We are able to resolve most cases to our client’s satisfaction by administrative practice before the Internal Revenue Service. We try to protect clients from the expense and stress of litigation. But when necessary we litigate for clients. We prefer to litigate in U.S. District Court or the U.S. Court of Federal Claims. We litigate with passion and skill, obtaining excellent results for our clients.
If you have a Federal tax controversy, please give us a call to confidentially discuss it:
Stephen J. Dunn, Esq.
Tel.: (248) 643-8130