IRS Controversy & Tax Litigation Services
In representing our clients before the Internal Revenue Service, we combine trial-tested litigation skills with up-to-date substantive tax experience. This combination enables us to take on the most challenging cases and achieve outstanding results for our clients.
We have proven skills and extensive experience in all aspects of tax controversy and litigation:
- Managing IRS audits
- Filing and presenting protests to IRS Appeals
- Negotiating litigation settlements
- Trying cases in court
Our active controversy and litigation docket keeps us at the cutting edge of evolving administrative and judicial practice and procedures, strategy, and tactics.
Resolving IRS Administrative Controversies
Pre-controversy advice and counsel. Our tax attorneys combine litigation and substantive tax experience to assist clients in effectively anticipating and planning for future controversies. Often, when the tax treatment of an item or transaction is challenged, the ultimate resolution is influenced significantly by actions taken or not taken when the transaction was planned, implemented, or first reported. With this in mind, we provide experience-based advice on reporting, disclosure, document retention, and other pre-controversy matters.
Audit controversy skills. We effectively use all available procedural techniques, including pre-filing agreements (PFAs), requests for technical advice, Fast Track Appeals resolution, Early Referral, and other IRS practices and programs. We have extensive experience with IRS summonses, enforcement proceedings, and joint defense agreements.
Individual and coordinated IRS and Treasury settlement efforts. We fashion creative and effective approaches to settlement. Our experience encompasses not only direct negotiations for single clients, but also group representations of taxpayers with the same or similar issues. We work hard to achieve favorable results, identifying the most effective approach, whether it be with the examining agent, LB&I, OTSA, Chief Counsel, the Office of the Commissioner, Treasury, or elsewhere.
IRS Appeals controversies. We prepare protests and negotiate with IRS Appeals to achieve favorable settlement results, and routinely appear before Appeals offices across the country, using all available Appeals tactics and strategies, including early referral and Post Appeals Mediation, either to achieve settlement or to position the case to proceed most effectively into litigation.
At Pendragon Law Group, we will review your situation with you and discuss with you all available options. You can reach an attorney by calling (206) 781-3443. Call us now and learn what options are available to you.
My entire experience with Pendragon Law couldn't have been better. They put me at ease and handled my case with the utmost precision and professionalism.
