Green & Sklarz has extensive experience in civil tax controversies and litigating tax matters throughout the country in what has become a national practice. We regularly represent clients before all federal and state taxing authorities, including the Department of Justice Tax Division, the United States Trustee’s Office, the Internal Revenue Service (“IRS”) and the New York and Connecticut Departments of Revenue (“DRS”). The firm responds aggressively, yet realistically, to any tax challenge raised by a government taxing authority. As a result of the firm’s many years of practice in this area, we have a unique and unusually deep understanding of government agencies’ practices and procedures. We pride ourselves on being able to efficiently and effectivly counsel our clients through the administrative process and help them achieve the best results possible.
The firm regularly represents clients who seek to challenge a proposed civil tax liability, who need to work out an arrangement to resolve a past tax debt, or who failed to file tax returns. The firm has negotiated hundreds of payment arrangements with the Internal Revenue Service and Connecticut Department of Revenue Services. We have represented taxpayers through voluntary disclosures, thereby both avoiding criminal prosecution and limiting civil penalties on behalf of clients.
Our objective in all matters is to resolve issues quickly, efficiently, and successfully. Though we always seek ways to resolve tax controversies prior to litigation, we are prepared to take a matter to trial when this is to our client’s advantage. Our experience encompasses all facets of negotiation with tax authorities, and all phases of tax litigation, including responding to audits, summonses and subpoenas, preparing administrative protests and petitions, discovery, depositions, dispositive motions, trials, and appeals. We also represent clients faced with summonses or subpoenas demanding documents or testimony in connection with a tax matter.
Our firm is frequently asked to represent a taxpayer when faced with a large tax liability due to their spouse or former spouse’s tax issues. We have represented taxpayers with innocent spouse and injured spouse claims, including IRS administrative appeals and United States Tax Court. We have also resolved these issues with the Connecticut DRS as well.
We handle federal tax matters of public and closely-held corporations, partnerships, and individuals. We routinely represent taxpayers before the Examination Division, Appeals Office, and Collection Division of the Internal Revenue Service. We try cases in the United States Tax Court, the United States District Court and the Federal Court of Claims. We regularly are involved with client offers in compromise, installment agreements, and innocent spouse relief applications, as well as handling all manner of payroll tax issues with the objective of minimizing personal liability for such payroll taxes. When necessary, we help clients use bankruptcy as a means of resolving their outstanding tax issues. In addition to income and payroll taxes, we are experienced in handling estate and gift tax matters, both audit examinations of returns as well as resolving valuation and payment issues.
We have also assisted clients with Bank Secrecy Act issues, including 8300 exams, where the taxpayer’s reporting compliance was brought into question and successfully resolve the issue with the special BSA examiners.
State Tax Issues
Along with our federal tax practice, we represent business and individual clients in connection with state tax issues including sales, payroll, and withholding income taxes. We have extensive experience in handling sales tax examinations and CT DRS Business Employment Tax Audit (“BETA”) Unit withholding tax examinations, representing clients at the administrative appeal level, and litigating cases in state court. We also represent taxpayers in Connecticut DRS domicile and residency cases.
Criminal Tax Investigations & Prosecutions
We routinely assist clients with criminal tax investigations opened up by the Internal Revenue Service (“IRS”), Department of Justice Tax Division, and the Connecticut Department of Revenue Services (“CT DRS”). We are involved in federal tax investigations from all over the country. Our extensive tax experience and experience dealing with the government serves us well in representing clients faced with federal and state criminal tax investigations. Our attorneys have represented businesses and individuals in cases involving failure to report income, allegations of fraudulent deductions, failure to collect and pay employment taxes, failure to collect and pay sales taxes, allegations of preparing false returns, failure to file returns, as well as other tax-related offenses.
As always, our goal is to make sure the government can prove its criminal charges and to that end have many successes having criminal investigations closed and returned to civil examination where they belong. In cases where there has been a crime committed, we work aggressively to make sure the government does not overstate its tax case and give our client every opportunity to minimize any tax loss calculation and, therefore, any sentence.
Once the criminal aspects of the case are concluded, we assist our clients with the civil aspects, handling any civil examination issue and collection enforcement activity by the government agencies, including orders of restitution.