Practice Groups

Tax Controversy and Dispute Resolution

 

If you have a tax matter at either the federal or state level, a successful result often turns on early intervention by an experienced tax lawyer representing your interest. Our practice group includes skilled tax attorneys who represent clients confronted with a wide variety federal and state tax issues. We represent clients before the Internal Revenue Service and the Indiana Department of Revenue in administrative, audit and criminal matters. If litigation is required, attorneys in our group have extensive experience before the U.S. Tax Court, U.S. District Courts, Indiana Tax Court and the federal and state appellate courts. Members of our group have served as attorneys with the Office of Chief Counsel for IRS, and the U.S. Department of Justice, Tax Division. Our clients include domestic and foreign corporations, business owners and individuals. We work with our clients and their advisors to craft creative and workable solutions for their tax problems. The types of matters we deal with include the following:

IRS audits and appeals

Tax liens, IRS levies and offers in compromise

IRS criminal investigations

IRS voluntary disclosures.


 

With audits we work with the clients’ accountants and advisors to develop a sound response strategy to minimize the time and expense of a protracted dispute with the tax authority. Our attorneys are well versed in the appeals process and have used tools such as “Fast Track Mediation” and Fast Track Settlement” when appropriate to avoid a lengthy appeals process.


Financial hardship for the client is often the result of a federal tax lien or a notice of levy placed on a bank account or served on an employer. We negotiate workable solutions with the taxing authorities to minimize that hardship for the client.


In criminal matters a successful result often turns on early intervention by an attorney well versed in criminal investigative techniques. Our attorneys can raise timely defenses that can minimize the risk of turning an honest mistake, exposed during an audit, into a criminal indictment.


The IRS voluntary disclosure program is intended to reach taxpayers who have undisclosed offshore financial assets. The program can be used to resolve the matter without the threat of criminal prosecution and substantial penalties. The rules, however, are complex and the program itself keeps changing. Our attorneys can advise the client throughout the process to ensure the best chance for success.


Regardless of your tax problem, the attorneys in our group are well versed in tax law and will provide you with the representation you need to defend your interests.