Tax Controversy & Taxpayer Representation
One of the Northeast's largest and most respected tax controversy practices. IRS, DOJ Tax Division, and state revenue matters, from audit through appeal, indictment through sentencing.
Tax controversy is the flagship of the firm. We represent individuals, business owners, public and closely held companies, and partnerships in the full spectrum of federal and state tax disputes — civil audits, administrative appeals, U.S. Tax Court litigation, refund actions in federal district court and the Court of Federal Claims, collection defense, and criminal tax investigations and prosecutions.
The practice is built around a specific claim: substantive fluency in the underlying tax law, combined with real experience across the government side of the table. A former Department of Justice Tax Division prosecutor, a former IRS Revenue Officer, and lawyers who have spent decades in Tax Court and before the DRS are the reason we can talk credibly to Revenue Officers, Revenue Agents, appeals officers, and Assistant U.S. Attorneys about how a given matter will actually resolve.
Clients most often come to us at the point where the exposure has crystallized: a notice of deficiency, a summons, a levy, a grand jury target letter, a state residency audit, a payroll trust-fund assessment. Our job is to reduce the number, remove the criminal risk, and get the client out of the collection system with terms they can live with.
Service scope
Individual, partnership, and corporate audits; estate and gift tax examinations; Bank Secrecy Act and Form 8300 examinations; response to summonses and third-party requests.
Protests to Appeals, docketed and non-docketed cases, and litigation in the U.S. Tax Court, U.S. District Court, and the U.S. Court of Federal Claims.
Offers in compromise, installment agreements, currently-not-collectible status, collection due process hearings, lien and levy defense, and coordinated bankruptcy strategy when discharge is on the table.
Representation in IRS Criminal Investigation matters and DOJ Tax Division prosecutions involving unreported income, false returns, employment and sales tax failures, and failure to file. Sentencing advocacy, restitution negotiation, and post-conviction issues.
Connecticut DRS and New York State audits and appeals across income, sales and use, payroll and withholding taxes, including CT DRS BETA Unit matters and residency and domicile disputes.
Domestic and offshore voluntary disclosure, reasonable-cause abatement, and structured cure of long-lapsed filing obligations.
Section 6015 relief across all three prongs, including litigation in Tax Court when Appeals denies.
941 liability, Trust Fund Recovery Penalty defense, responsible-person disputes, and employer worker-classification cases.
- Individual taxpayers facing audits, collection actions, or criminal investigation
- Business owners and closely held companies with payroll, sales, or income tax exposure
- Public companies and partnerships in federal and state controversies
- High-net-worth individuals in residency, domicile, and estate tax disputes
- Professionals and advisers under Circular 230, preparer penalty, or licensing scrutiny
- Clients referred by CPAs and enrolled agents when a matter turns adversarial
Aligned professionals
State and local tax planning, compliance, and audit defense.
IRS representation across all administrative levels; tax and bankruptcy support.
Civil and criminal tax controversy; national tax educator.
IRS representation and collection strategy; former Revenue Officer.
Civil and criminal tax defense, financial crimes, and complex federal litigation.
Trial and appellate litigation — white collar, civil rights, tax, and professional responsibility.
Bankruptcy, commercial litigation, and the intersection of tax and insolvency.
Tax preparation, IRS representation, and tax resolution.
Common questions
The IRS just sent a letter. Is it time to call a lawyer?+
Some notices are administrative and a CPA can handle them. Others — a 30-day letter, a notice of deficiency, a summons, a Revenue Officer visit, or anything from Criminal Investigation — change the posture of the matter and the privilege picture. When in doubt, call before you respond.
What is the difference between a civil audit and a criminal investigation?+
A civil audit measures the tax. A criminal investigation measures intent. The two can overlap, and statements made in an audit can be used in a later prosecution. If there is any risk the matter is criminal, the response strategy needs to be built for that from day one.
Can you actually settle with the IRS for less than what is owed?+
In the right facts, yes — through an offer in compromise, a partial-pay installment agreement, or bankruptcy discharge of qualifying taxes. It is not the answer in every case, and beware anyone who promises it before reviewing the file.
We haven't filed returns in years. What now?+
Cure the filings, contain the penalty exposure, and get in front of any criminal risk before the government moves first. Voluntary disclosure is a structured path when the facts support it.
Do you handle state matters, or only federal?+
Both. Connecticut DRS and New York State controversies are a core part of the practice, including sales tax, payroll, income tax, and residency audits.
How is the fee structured?+
Most controversy work is billed hourly with clear scope, and we set expectations on likely ranges early. Fixed fees are available for defined-scope matters such as an offer in compromise submission.
Ready to talk through the matter?
Confidential consultations. Call the firm directly, or send a short note and we'll respond.