Tax Litigation
Even a thorough transactional plan may be challenged. Tax disputes may arise with the Internal Revenue Service, the State, and Local Taxing Authorities. Defense of a reported transaction or business practice may become necessary.
An extensive component of tax litigation is negotiation with the Internal Revenue Service, the State, and Local Taxing Authorities. Aggressive Representation will in many cases avoid the need of risky and costly litigation. Some common issues are:
- A Refund Claim;
- A Deficiency Notice;
- A Failure to File a Tax Return;
- A Payroll or Sales Tax Liability;
- A Penalty and Interest Abatement;
- An Innocent Spouse Claim; or
- A Criminal Tax Defense Matter.