We Help Taxpayers Fight Back
You don't have to face the IRS alone. At DeWitt Law, we stand firm, we fight boldly, and we demand accountability. Tax problems with the IRS? Tax-related criminal charges? No intimidation here. We’re passionate defenders, relentless advocates, and proven winners. Your freedom, your peace, your future—it matters deeply. We're ready. Are you?
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.
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More Than a Law Firm
Team of Tax Professionals
Results
Our firm is committed to delivering results for our clients. We invite you to review a sample of representative tax litigation matters we have resolved for our clients.
Criminal Tax Case Involving Aircraft Purchases and Tennessee Use Tax Dismissed
DeWitt Law recently represented a taxpayer indicted in Benton County, Tennessee, for alleged failure to report and pay Tennessee sales and use tax related to multiple aircraft purchased out of state. The Tennessee Department of Revenue alleged that the aircraft were brought into Tennessee without proper tax reporting, leading to a criminal tax prosecution. Our firm thoroughly analyzed the state’s evidence, tax assessments, and the taxpayer’s compliance record. Through strategic…
DeWitt Law Defeats IRS Civil Fraud Penalty in Tax Court
DeWitt Law successfully represented a taxpayer in U.S. Tax Court who had been assessed the civil fraud penalty under Internal Revenue Code § 6663—a 75% penalty imposed when the IRS alleges intentional fraud. The IRS claimed the taxpayer knowingly underreported income, seeking to add a significant penalty to an already large tax bill. However, our firm challenged the government’s claims, highlighting inconsistencies in the evidence and presenting a compelling defense…
DeWitt Law Stops IRS from Seizing Client’s Property Over Ex-Husband’s Tax Debt
After our client’s divorce, the IRS sued her in federal district court for tax debts that were entirely her ex-husband’s responsibility. The IRS claimed they could take property she received in the divorce, even though she had no role in creating the tax problem. They filed the lawsuit trying to foreclose on her property and tie her to more than a million dollars of tax debt that wasn’t hers. DeWitt…
$208,984 Tax Liability Reduced to $107,495 in U.S. Tax Court
Taxpayer was audited by the IRS for multiple tax years, resulting in a Notice of Deficiency proposing additional tax in the amount of $208,984. The basis for the Notice of Deficiency was disallowed Schedule C contract labor and cost of goods sold. DeWitt Law filed a Petition in U.S. Tax Court challenging the Notice of Deficiency. The Court entered a Decision reducing the tax liability by over 50% to $107,495.
$220,187.27 Tax Liability Reduced to $10,699.67 in U.S. Tax Court
Taxpayer received a Notice of Deficiency proposing additional federal income tax (plus penalties) in the amount of $220,187.27. The basis for the Notice of Deficiency was alleged unreported capital gain income from the sale of the Taxpayer’s home that was renovated. DeWitt Law represented the Taxpayer and filed a Petition in U.S. Tax Court. After completing discovery, the property’s basis was substantially increased by the IRS, resulting in a Decision…
$436,327.20 Tax Liability Reduced to $33,364 in U.S. Tax Court
After being audited by the IRS, the Taxpayer received a Notice of Deficiency proposing additional federal income tax (including penalties & interest) in the amount of $436,327.20. The basis for the Notice of Deficiency was disallowed Schedule C business expenses (including contract labor and supplies) on the Taxpayer’s 2021 and 2022 federal income tax returns. DeWitt Law represented the Taxpayer and challenged the Notice of Deficiency by filing a Petition…