COMPLEX TAX CONTROVERSY
We represent domestic and multinational corporations involved in IRS audits, investigations, and administrative appeals. When an IRS audit or investigation potentially involves complex tax and legal issues, we assist clients and their CPAs prepare responses to IRS information document requests and other inquiries. We help the client organize the relevant tax, financial and legal documents to factually support their tax return positions, and prepare written responses to explain the taxpayer’s legal and tax positions. When a legal basis exists to dispute an IRS assessment, we represent clients in IRS administrative appeals. We provide the legal and tax analysis, as well as written and oral arguments before the IRS appeals officer to defend the client’s tax and legal positions.
A TEAM APPROACH
We typically work closely with a company’s certified public accountant in any IRS audit or appeal. In some instances, a client’s CPA may want the backing of a tax attorney in an IRS audit. If the CPA or client is concerned that complex legal issues will be examined, the client and CPA may want an attorney involved for legal analysis and advocacy at the audit stage. In other circumstances, the client or CPA may anticipate that further legal proceedings such as an administrative appeal, will likely result from the audit. In those situations, it may make sense to involve legal counsel at an early stage to ensure the client’s case is presented in the best possible light to create a record for the IRS appeals officer.