Resolving Civil Tax Litigation Problems
Civil Tax Litigation Attorney Resolving Tax Problems
An IRS audit is usually the first step in a tax controversy matter. If the audit cannot be resolved with the IRS Revenue Agent at the Audit/Examination stage, then the matter will generally proceed to the Appeals Office. An Appeals Officer has more discretion to settle the matter as they can consider the “hazards of litigation” associated with the case. In other words, the Appeals Officer should calculate the possibility of the taxpayer prevailing if the matter went to Tax Court and offer a settlement based upon that possibility. However, if your representative does not have significant experience with Tax Court litigation then the threat of proceeding to trial will not be considered. That is just one reason, among many, why is it so important to hire an experienced tax attorney at the beginning of the audit examination. o
If the tax matter is not resolved at the Appeals level, then the taxpayer has the right to file a Petition with the United States Tax Court. At this stage the tax issues involved are generally complex and a cost/benefit analysis to determine whether a trial in Tax Court (including the anticipated attorneys fees and costs) is beneficial is usually conducted.
Before you hire an attorney to represent you in U.S. Tax Court – or even at any stage of an audit examination – you should ask the prospective attorney how much experience they have with Tax Court litigation and quest that list as proof. Mr. Leonard has made over 100 appearances in U.S. Tax Court over the last several years. A significant number of Mr. Leonard’s clients are referred by their trusted advisors, including CPAs, investment advisors and lawyers.
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If you have been selected for an audit examination or have a matter ready to proceed to Tax Court and want to discuss the development and implementation of the right action plan for your tax litigation issue, call 818-224-7935, or contact us online to schedule a free consultation. We serve clients in Woodland Hills, Los Angeles and the San Fernando Valley and across the entire nation.