Should you be unable to resolve the IRS’ audit determination you may be facing the prospect of litigating the dispute in court. One of the first considerations will be in which court to try the dispute. A number of courts has jurisdiction to determine federal taxes.
The firm handles all types of tax litigation cases including litigation in the U.S. Tax Court which involve a taxpayer contesting the IRS’s determination that the taxpayer owes additional tax, and/penalties, and which provides a forum for a taxpayer to request a determination of the deficiency prior to paying the tax allegedly owed. Other cases that may be considered by the Tax Court include Collection Due Process (CDP) cases where a taxpayer requested a hearing with an independent CDP officer in response to a notice of Federal tax lien or notice of intent to levy, Innocent Spouse Program cases in which a taxpayer who filed a joint return with a spouse or ex-spouse may apply for relief of tax, interest, and penalties if he/she meets specific requirements, Abatement of Interest cases of disputed interest on tax deficiencies or payments in which IRS error or delays may have contributed to the assessed interest, and Tax-exempt Status cases where an organization disputes IRS’s revocation or denial of tax-exempt status.
Refund cases involve taxpayers seeking refunds of claimed overpayments after the tax, penalties and interest have been fully paid and are litigated in the U.S. Federal District Courts or the U.S. Court of Federal Claims. U.S. Bankruptcy Courts also has jurisdiction to determine federal tax issues.
Our Law Office has experience in all forums, and is more than qualified to represent you in the Court chosen to litigate your tax dispute.