Most tax attorneys handle tax planning and they rarely handle tax controversies. Tax litigation lawyers represent clients who have tax problems with the IRS or state taxing agencies. If you have a tax dispute with the government, we can help you. Mr. Rowland is a former IRS attorney. He taught Federal Tax Procedure for years at the Golden Gate University Graduate School of Taxation, and he was head of the California State Bar Tax Procedure and Litigation Committee.
We represent clients with tax problems involving the Internal Revenue Service, the California Franchise Tax Board and Board of Equalization, as well as county and city tax agencies. We settle most of our cases before trial but we have no reluctance to litigate your case in court if that’s the appropriate route to take.
We provide representation in audits, if it is appropriate to call on our specialized expertise at that stage. Most of our representation is provided later in the proceeding, in administrative appeals and in litigation.
TAX LIENS / LEVIES
We also represent taxpayers who can’t pay their taxes. These services involve negotiation of installment agreements and offers in compromise and we sometimes advise clients to seek relief from taxes through bankruptcy. We always verify whether the taxing agency has followed the proper legal steps to assess the tax and whether the statute of limitations is still open.
CIVIL AND CRIMINAL TAX PENALTIES
When clients are facing civil and criminal tax penalties, experienced and sensitive representation is required. We are particularly proud of the results we have achieved in these cases.
INNOCENT SPOUSE RELIEF
Another important area in our practice is spousal liability or so-called innocent spouse relief. We have handled many of these cases, frequently with positive results. One case we are particularly proud of is Klimenko v. Commissioner, T.C.M. 1993-340. In this case, a police officer was allowed innocent spouse relief after a trial, when the IRS Appeals Office had refused to offer any concession whatsoever.
We try to provide the optimal solution for difficult tax problems. The right approach and the right answer will depend greatly on the specific facts and circumstances. We start by meeting with the client to discuss their situation and to determine the best course of action. We involve the client at every important step in the decision making process.
We understand that dealing with a tax problem can be very stressful. Our goal is not only to minimize the taxes our clients owe, but also to reduce their stress. We take the responsibility of dealing directly with the tax authorities, and our clients know that we have decades of experience in resolving tax controversies.