Tax Controversy
Representation in IRS disputes, audits, collections, and tax debt matters — for individuals and businesses.
Tax controversy covers any situation where you are in dispute with a taxing authority — whether that's an IRS audit, a balance you disagree with, penalties, or aggressive collection actions like levies and garnishments. Having an attorney who understands both the law and IRS procedures can materially affect the outcome of these situations.
Tax Lawman represents individuals and businesses in tax controversy matters, from initial IRS correspondence through appeals. The focus is on practical resolution: understanding what the IRS is actually asking for, responding correctly, and pursuing the most favorable outcome available under your specific facts.
What We Handle
Tax Controversy Services
IRS Notices & Correspondence
Receiving an IRS notice is alarming, but it does not always mean you owe additional taxes. Many notices are informational, request clarification, or have straightforward responses — but they all have deadlines.
- CP2000 notices (proposed changes to your return)
- CP501–CP504 (balance due notices)
- Audit notices and information requests
- Notices of intent to levy or lien
- Examination correspondence
Ignoring an IRS notice does not make it go away — it typically escalates the situation. An attorney can help you understand what the IRS is actually asking for and respond appropriately.
IRS Audit Representation
An IRS audit is a review of your tax return and financial records. It can be conducted by mail (correspondence audit) or in person (office or field audit). Having qualified representation during an audit protects your rights and helps ensure the process stays focused.
- Correspondence audits (mail-based)
- Office audits (at an IRS office)
- Field audits (at your home or business)
- Business audits and records reviews
- TCMP and research audits
You have the right to have an attorney present during an IRS audit. You are not required to speak directly with the IRS examiner if you have representation.
Back Taxes & Unfiled Returns
If you have years of unfiled tax returns, the longer you wait the more interest and penalties accumulate. Getting back into compliance involves preparing missing returns strategically while minimizing your liability where possible.
- Filing delinquent returns for prior years
- IRS voluntary disclosure
- Addressing substitute returns filed by the IRS
- Minimizing penalties for late filing
- Negotiating payment plans for resulting balances
The IRS may file substitute returns on your behalf if you fail to file — often resulting in a larger balance than necessary. Filing your own returns is almost always more favorable.
Tax Debt Resolution
Owing the IRS money does not necessarily mean you must pay it all immediately. Several programs exist to help qualifying taxpayers manage or resolve tax debt. The right strategy depends on your specific financial situation.
- Installment agreements (payment plans)
- Currently Not Collectible (CNC) status
- Offer in Compromise (OIC) for qualifying taxpayers
- Innocent spouse relief
- Bankruptcy considerations involving tax debt
Offers in Compromise are legitimate but not universally available. The IRS accepts a small percentage of OIC applications. Evaluating eligibility honestly before applying is important.
Penalty Abatement
The IRS can impose significant penalties for late filing, late payment, and underpayment. In some cases, these penalties can be reduced or removed entirely through a penalty abatement request based on reasonable cause or first-time abatement programs.
- First-time penalty abatement (FTA)
- Reasonable cause penalty relief
- Statutory exceptions
- Administrative waiver requests
- Interest reduction (limited circumstances)
Not all penalties qualify for abatement. An attorney can evaluate your situation and prepare a well-supported abatement request where appropriate.
Tax Appeals
If you disagree with an IRS decision — such as the result of an audit or a rejected penalty abatement — you have the right to appeal. The IRS Office of Appeals is an independent function within the IRS designed to resolve disputes without litigation.
- IRS Office of Appeals hearings
- Collection Due Process (CDP) hearings
- Tax Court petition (when appropriate)
- Offer in Compromise appeals
- Audit reconsideration
Appeals must be filed within specific time windows. Missing a deadline can foreclose important options. Acting promptly on IRS decisions is critical.
Important Disclaimer
The information on this page is for general educational purposes only and does not constitute legal advice. Tax situations vary significantly, and outcomes depend on the specific facts and circumstances of each case. No result or outcome is guaranteed. Past results do not indicate future performance. Consulting with a tax attorney about your specific situation is the only way to get advice applicable to your case.
Common Questions
Tax Controversy FAQ
Ignoring an IRS notice typically makes the situation worse. The IRS will continue the audit process without your input, often resulting in a larger assessment than would have resulted with proper representation. The IRS may eventually issue a Statutory Notice of Deficiency (90-day letter) — missing that deadline eliminates your right to petition Tax Court.
In some cases, yes. The IRS offers First-Time Abatement (FTA) for taxpayers with a clean compliance history, and Reasonable Cause relief for taxpayers who can show a legitimate reason for not complying — such as illness, natural disaster, or reliance on professional advice. Not all penalties qualify, and success depends on your specific situation.
An installment agreement is a payment plan with the IRS that allows you to pay your tax debt over time in monthly installments. There are different types — streamlined, partial pay, and full-pay agreements — with varying eligibility requirements. Setting up an installment agreement can prevent more aggressive collection actions like levies.
An Offer in Compromise allows qualifying taxpayers to settle their tax debt for less than the full amount owed. It is based on your ability to pay, income, expenses, and asset equity. The IRS accepts a relatively small percentage of OIC applications. An honest evaluation of eligibility before applying saves time and money. It is not a universal solution, and those who do not qualify may waste time and fees pursuing it.
A wage levy (garnishment) is a collection action where the IRS instructs your employer to withhold a significant portion of your paycheck and send it to the IRS. It can be released by entering into an installment agreement, establishing CNC status, or through other resolution options. Acting quickly is important once a levy notice has been received.