We have significant experience in tax administrative practice and procedure. Our practice handles federal tax issues, and we serve clients nationwide. For decades, we have worked closely with revenue agents during audits, including the IDR (information document request) process, notices of proposed adjustments/revenue agent reports (also called the 30-day letter), statutory notices of deficiency/the “90-day” letter, notices of final partnership administrative adjustments (FPAAs in TEFRA cases), and notices of final partnership administrative adjustments (as well as FPAAs in BBA cases), summonses and summons enforcement, fast-track mediation, and consideration by IRS Appeals.
We have significant tax experience with domestic and international tax issues and civil tax penalties. Those issues span a wide area of subject areas affecting individuals, partnerships, and corporations.
If you receive a letter from the IRS, let’s talk.
We have intensive experience in tax litigation and litigation support. Our practice handles federal tax issues, and we serve clients nationwide. We regularly litigate cases in U.S. Tax Court, as well as have had intensive involvement on significant tax cases litigated by the U.S. Department of Justice in U.S. District Court and the U.S. Court of Federal Claims. We develop litigation strategy, prepare and respond to discovery, document management, settlement discussions, exhibit management, expert witnesses, pretrial motions, pretrial memorandum, and writing and reviewing post-trial briefs. The case types include partnership cases (TEFRA/BBA), deficiency cases of corporations and individuals, whistleblower cases, collection due process cases, and innocent spouse cases.
We also can assist as co-counsel in your case and help you assist your client with your case.