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Nothing is as stressful as an audit letter or collection notice from the Commissioner of the Internal Revenue Service.

Anxiety resulting from dealing with the Internal Revenue Service is certainly understandable given the resources available to the IRS in pursuing a tax dispute against individual and business taxpayers.  Currently, the IRS operates on an annual budget of almost $12 billion, with approximately 80,000 employees in five (5) operating divisions – the Large Business and International division (LB&I), the Small Business/Self-Employed (SB/SE) division, the Wage and Investment (W&I) division, the Tax Exempt & Government Entities (TE/GE) division, and the Criminal Investigation Division (CID).  It is advised and represented by the Office of Chef Counsel for the Internal Revenue Service, an agency within the Treasury Department whose sole client is the IRS.  It is staffed with approximately 1,400 attorneys who are assigned among the IRS National Office and the major operating divisions of the agency.  The IRS also receives legal assistance from the main Treasury Department, the Tax Division of the Department of Justice, and the local United States Attorneys’ Offices.  Obviously, the IRS’s resources are unmatched compared to those available to an individual or business taxpayer.

Nevertheless, when the Internal Revenue Service is in pursuit, a taxpayer does have rights, the most of important of which is to consult and retain qualified tax counsel as your representative (see Taxpayer Bill of Rights # 9 and Tax Tip 2018-60). Disputes with the IRS will not be resolved in your favor without a tax lawyer who knows and is experienced in the substantive tax law underlying the contest and also the administrative law, procedures, and best practices for resolving your federal tax controversy with the IRS.

The Law Offices of Matthew I. Root has more than 30 years’ experience litigating and otherwise resolving the most complex federal tax issues, and can do the same for you.  During these 30 years, we have practiced extensively in managing audits, administrative appeals, including mediation, fast-track and other alternative dispute resolution mechanisms, bankruptcies (chapters, 7, 11 and 13), including bankruptcy tax cases, tax litigation in the U.S. Tax Court, and refund cases in the Federal Court of Claims and Federal District Courts, collection issues, including lien priority disputes, insolvencies, receiverships, decedent’s estates, estate tax cases, summons cases (collection and examination), Freedom of Information Act (FOIA) cases, disclosure (I.R.C. 6103) cases, collection suits, including transferee, fraudulent conveyance, and alter-ego cases, and offers-in-compromises (OIC).

Headquartered in Buffalo, N.Y. yet representing and counseling taxpayers throughout the eastern United Sates, our office focuses on assisting taxpayers, individuals or businesses – small and large, successfully settle or otherwise resolve their disputes with the Internal Revenue Service.  Our expertise and experience in handling these matters means you can be assured your tax dispute with the IRS is being properly handled and that there is nothing further for you to do.  You can have confidence that your tax question will ultimately be disposed of at the least cost to you.

You can be assured that we have handled the type of case you are involved in with the IRS.  Whether your particular tax controversy with the IRS involves a dispute whether there is a deficiency in your reported federal tax liability, or a dispute whether you are able to pay your tax liability, or some other matter, such as a FOIA case, we have the experience and skill to ensure you ultimately will owe and pay the lowest possible amount in tax. Our firm can successfully guide and represent you to achieve a favorable resolution of your tax contest.

If you have a tax dispute with the IRS your should contact as soon as possible, to review your tax problem.  Ignoring a federal tax issue will not solve the matter, and will in fact, only make things worse, as the passage of time does not improve disputes with the Internal Revenue Service.  We will clearly and fully explain, at no cost, all of your options for dealing with the IRS, as well as our recommendations.  We will answer your questions to ally your concerns so you are able to make a fully informed decision on how to proceed.  We look forward to hearing from you.

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