Tax Audits and Examinations:
We represent taxpayers/clients be they individuals, businesses, non-profit entities, and estates in audits by the IRS, State and/or Local Taxing Authorities.IRS and State Taxing Authority Appeals:
If taxpayers/clients are unhappy with the outcome or proposed adjustments by the respective taxing authority at the conclusion of the audit or examination, we file a formal appeal to the IRS Appeals Division or the applicable administrative state entity setting forth all relevant facts and applicable law advocating the taxpayers positions and thereafter negotiating a resolution if possible at appellate conferences and/or administrative hearings.United States Tax Court:
If the taxpayers/clients are still dissatisfied with the outcome at the appeals level or have received a Notice of Deficiency, we as members of the Tax Court Bar can file a petition with the Tax Court and represent our clients in subsequent proceedings and negotiations with attorney's from the Office of Chief Counsel for the IRS.United States District Court and Court of Appeals:
Taxpayers/clients may alternatively decide to challenge proposed adjustments to their individual or business tax returns in district court after receiving a Notice of Deficiency or a denial of a claim for refund. As a member of several federal district courts, we are capable of representing clients in multiple states. If either the taxpayer and/or the government are dissatisfied with the ruling in their tax court case and appeals it to the circuit court, we are admitted to the Third Circuit Court of Appeals where we can brief and argue cases before that court.Criminal Tax Investigations
: When a return is filed that is deemed fraudulent by the IRS, and could have potential criminal tax implications an administrative or grand jury investigation can be initiated by the IRS and which are typically conducted by its Special Agents. Extreme caution should be exercised in the handling of such because the investigation/grand jury process can present an opportunity to resolve the case prior to having it referred for criminal prosecution or having an indictment returned. We have experience representing clients who are the subject of such administrative investigations and/or are the target of a grand jury.Non-Filing and/or Unfiled Tax Returns and Voluntary Disclosure
: We advise clients and assist them in analyzing the benefits and risks in entering into and participating in both the traditional domestic Voluntary Disclosure Program and the Overseas Offshore Voluntary Disclosure Program. We assist our clients in navigating the complexities of each of these programs with the single purpose of eliminating exposure to criminal prosecution for those wishing and willing to disclose either the existence of unfiled returns or the desire to amend previously filed erroneous tax returns. Participation in the Offshore Voluntary Disclosure Program also has the benefit of substantially reducing civil penalties for those taxpayers who have not disclosed offshore accounts and have failed to file FBAR returns.