Experienced Tax Lawyer
A tax controversy refers to any dispute between a taxpayer and a taxing authority—such as the Internal Revenue Service (IRS) or the Massachusetts Department of Revenue (DOR)—regarding the reporting or payment of taxes. These disputes can involve individuals, businesses, or nonprofits and often center on disagreements over the amount of taxes owed, the classification of income or deductions, or the interpretation of tax laws. Tax controversies can range from simple matters, like correcting a filing error, to complex cases involving large financial stakes and serious legal consequences.
There are several stages in the resolution of a tax controversy, and understanding the distinctions is critical. In cases involving the IRS, a tax controversy proceeds according to the following stages:
- Audit: An IRS audit is typically the first step, where the IRS reviews a taxpayer’s return to verify accuracy.
- Appeal: If the taxpayer disagrees with the audit findings, they can pursue an IRS appeal through the IRS Office of Appeals, which offers an independent review of the case to resolve disputes without litigation.
- Litigation: If a resolution still isn’t reached after an IRS appeal, the matter can escalate to tax litigation, where the dispute is brought before either the U.S. Tax Court or a U.S. Federal District Court.
Tax controversies can arise in a number of ways, including underreported income, misclassified workers, improperly claimed deductions or credits, failure to file returns, or issues with international tax compliance. Businesses may also face disputes over payroll or sales taxes, while individuals might face challenges related to cryptocurrency reporting, offshore accounts, or inherited assets. Sometimes taxpayers aren’t even aware of an issue until they receive a notice or are selected for audit, making it all the more important to respond quickly and appropriately.
Given the complexity of tax law and the potential financial and legal risks, it is critical to have experienced legal representation when facing a tax controversy. A skilled attorney can help assess the validity of the IRS or state’s position, prepare a strong response, and advocate on your behalf throughout the process. Without legal guidance, taxpayers may unintentionally make admissions, miss key deadlines, or agree to unfavorable settlements. Effective representation not only protects your rights but also increases the likelihood of a favorable resolution.
Our firm is committed to helping clients resolve tax controversies with skill, strategy, and discretion. Whether you are facing an audit, preparing an administrative appeal, or need representation in court, we provide experienced legal counsel tailored to your specific situation. We understand the stakes and the stress that come with tax disputes, and we work diligently to achieve fair outcomes while minimizing disruption to your finances and your life.
