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Tax controversy is the focus
Nothing is referred out at the point where it becomes difficult, and nothing is handed to unlicensed case staff.
Before the IRS — administrative stages
EXAMINATION
IRS audits
Correspondence, office, and field examinations. The firm takes over contact with the examiner, answers information requests, and holds the scope to the years and issues actually under review.
ADMINISTRATIVE REVIEW
IRS Appeals
An independent function that weighs how a case would fare in litigation. Most disputes end here, and it is the last opportunity to settle before a petition is required.
RELIEF
Penalty abatement
Reasonable cause, first-time abatement, and Appeals of penalty determinations — including penalties that have grown larger than the tax underneath them.
RELIEF
Innocent spouse relief
Relief from joint liability where one spouse had neither knowledge of nor benefit from the understatement on a joint return.
In court — when the administrative route runs out
LITIGATION
United States Tax Court
Deficiency petitions from filing through pretrial development, settlement, and trial. Filing suspends assessment, so the IRS cannot collect while the case is pending.
ENFORCEMENT
Collection defense
Liens, levies, and wage garnishments. Collection Due Process hearings, Offers in Compromise, installment agreements, and Currently Not Collectible status.
Specific exposures
EMPLOYMENT TAX
Trust Fund Recovery Penalty
Defense of penalties assessed personally against owners and officers for unpaid payroll taxes, and disputes over whether workers were properly classified.
CROSS-BORDER
Offshore disclosure
Unfiled FBARs and information returns, streamlined filing procedures, and the penalty exposure that follows undisclosed foreign accounts.
YOUR ACCOUNTANT
Protecting what you tell your CPA
What you tell an accountant is only narrowly protected, and not at all in a criminal matter. Where the facts are sensitive, your accountant can be brought in through the firm for full attorney-client privilege instead.
WASHINGTON STATE
Department of Revenue
State excise and B&O tax audits, assessments, and administrative appeals before the Washington Department of Revenue.
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