Tax Controversies, Appeals and Litigation

Tax disputes should never be taken lightly.

The IRS and taxing authorities at the state and local levels typically draw on vast resources – including highly experienced legal teams – to pursue cases against individuals and businesses. If you or your company are embroiled in a tax controversy, working with knowledgeable and experienced attorneys well-versed in this area of law is essential.

Smith Legacy Law provides informed legal counsel and advice to high-net-worth individuals and businesses facing complex tax controversies, appeals, and litigation. Whether you’re seeking to resolve a tax dispute with the IRS or a state or local taxing agency, they’ll leverage their formidable skill to minimize your liability and protect your rights.

Our Capabilities

Our attorneys’ in-depth knowledge of tax law at the local, state, and federal levels allows Smith Legacy Law to help clients confidently navigate all manner of tax controversies, including tax audits, administrative appeals of audit results, and tax-related litigation.

IRS Tax Audits

The IRS is authorized to audit the federal returns of individuals and businesses. If you or your company become the subject of an audit, expect the agency to take a deep dive into financial documentation and accounts to ensure accurate reporting and compliance with the law. If the audit results in a higher liability, you can either agree or disagree and take appropriate action from there.

While they are undoubtedly stressful and intrusive, it’s been our experience that successful resolution of federal tax disputes often begins with the audit. Our attorneys can assist with ADRs, liaise with the IRS, formulate an effective audit strategy, and even manage the entire audit process on your behalf.

IRS Administrative Appeals

When tax disputes can’t be resolved at the audit level, a taxpayer may choose to pursue an administrative appeal. IRS Appeals is a neutral body within the IRS dedicated to resolving disputes between taxpayers and the agency without the need for litigation.

Their deep understanding of the IRS administrative appeals process allows our attorneys to seamlessly guide clients through complex appeal procedures and negotiate effectively on their behalf.

U.S. Tax Court

Litigation is generally an option of last resort, as most IRS tax controversies resolve at the administrative appeals level. While the recipient of an unfavorable decision in an IRS administrative appeal may petition one of three federal courts, most will head to the U.S. Tax Court, which is overseen by neutral judges with substantial tax law expertise.

In our experience, the most favorable outcomes are typically achieved when the IRS is aware that the taxpayer’s legal counsel is willing and able to litigate if necessary. In addition to their solid understanding of tax matters, our attorneys are seasoned litigators capable of providing our clients with skillful courtroom representation when required.

State and Local Tax Litigation

Our attorneys also have broad tax litigation experience at the state and local levels. They are available to provide assistance with matters involving income tax, sales and use tax, property tax, and more.

Connect with Our Tax Litigation Professionals Today

At Smith Legacy Law, our tax controversy attorneys are able to draw on a wide array of resources typical of large firms yet, at the same time, offer a personalized level of service only available from a boutique practice. From administrative appeals to the courtroom, they successfully maneuver clients through every step of the tax litigation process, working tirelessly to protect our clients’ interests.

If you’re facing a tax controversy, litigation, or appeal, connect with Smith Legacy Law today.