Tax Controversy Representation

We provide various legal services to aid in the resolution of tax problems for business owners and professionals, including the following:

  • Offers in compromise
  • Installment agreements
  • Handling bank levies
  • Handling liens
  • IRS and FTB appeals representation
  • Tax Court representation

The principal reason a taxpayer may want to petition the tax court is for a redetermination of a tax deficiency proposed by the IRS.  If the taxpayer and the IRS cannot settle the issue, the IRS will issue a Notice of Deficiency.  At this point, the taxpayer may litigate the matter, without paying the tax, by filing a petition with the Tax Court within 90-days of the notice, or within 150-days if the notice is addressed to a person outside of the US.  After the petition is filed, the matter is docketed with the Tax Court, and the IRS must generally answer the petition within 60-days of the date of service of the petition.

In addition to predetermining deficiencies, the Taxpayer Bill of Rights and the Service Restructuring and Reform Act of 1998 also provided the Tax Court with additional review of the following tax controversy matters, without the need for a notice of deficiency:

  • Collection due process.  A taxpayer may seek Tax Court review within 30-days of an IRS Appeals Office denial of relief associated with an Intent to Levy or Notice of the Filing of a Tax Lien.
  • Relief from joint and several liability.  A joint-filing taxpayer claiming “innocent spouse” relief can seek Tax Court review, if the IRS issues a Notice of Disallowance of Relief.
  • Interest abatements.  The Tax Court has jurisdiction to determine whether the IRS abused its discretion by refusing to abate interest.
  • Worker classification and amount of employment taxes owed.  An employer who has received a Notice of Determination Concerning Worker Classification may seek Tax Court review within 90-days of the notice.

Contact us at (949) 482-1850 today.  We know how to effectively handle your tax situation.  Learn more below: