Tax Litigation
While most tax issues are resolved through administrative channels, some issues must be resolved in court. Litigating a tax issue in court requires special attention to court rules, evidence, jurisdiction, and the burden of proof. Examples of federal tax issues that are often resolved in court include:
- Challenging the results of an audit (after a Notice of Deficiency has been issued)
- Defending against lawsuits initiated by the IRS to foreclose property
- Challenging collection action taken by the IRS (after a Notice of Determination has been issued)
- Challenging IRS penalty assessments
- Trust Fund Recovery Penalty
- Tax Return Preparer Penalties
Tax litigation is highly fact-intensive and often involves complex legal issues. It is critical to seek the assistance of an experienced tax attorney when challenging tax matters in court. The skill of a tax attorney can represent the difference between a tax issue being decided on its merits or dismissed on a technicality. Our attorneys regularly litigate tax cases in federal courts (including U.S. Tax Court) and state trial courts. We invite you to request a consultation with a tax attorney if you are interested in resolving a tax issue in court.