Tax Controversy
Criminal investigation, civil exposure, and reputational risk handled as one matter.
When the IRS or a state taxing authority is challenging you, the stakes can escalate quickly. An audit can become a significant assessment. Unpaid taxes can lead to liens, levies, and seizures. A civil investigation can uncover potential criminal exposure. And a tax dispute involving a business can threaten far more than the amount the government says is due.
Tax controversy is the flagship practice at Green & Sklarz. We represent individuals, business owners, closely held and public companies, and partnerships in serious federal and state tax disputes, from the first contact with the government through administrative appeals, litigation, collection proceedings, and criminal investigations.
Effective tax controversy representation requires more than knowing the tax law. It requires understanding how the IRS, the Department of Justice, and state taxing authorities actually investigate, evaluate, negotiate, and litigate cases.
Our team brings that perspective to every matter. It includes a former Department of Justice Tax Division prosecutor, a former IRS Revenue Officer, and tax controversy attorneys with decades of experience dealing with IRS Revenue Agents and Revenue Officers, IRS Appeals, the Connecticut Department of Revenue Services, the U.S. Department of Justice, and the federal courts.
That experience helps us evaluate not only what the law says, but what the government is likely to do next and how best to respond.
Clients often contact us when a tax problem has reached a critical point: a substantial audit assessment, Notice of Deficiency, IRS summons, federal tax lien, levy or threatened seizure, Trust Fund Recovery Penalty investigation, state residency audit, criminal tax investigation, or grand jury subpoena or target letter.
Some clients come to us much earlier. That can be an advantage. The sooner we become involved, the more opportunity we may have to shape the record, control communications with the government, preserve legal options, and prevent a tax problem from becoming a larger one.
Every tax controversy is different, but our objective is straightforward: understand the government's case, identify the client's real exposure, and develop the strongest strategy for resolving it.
That may mean challenging an assessment, negotiating with the government, stopping enforced collection, resolving tax debt on workable terms, defending a case in court, or identifying and managing potential criminal exposure.
When the government is focused on you or your business, you should have a tax controversy team that understands both the law and the government across the table.
Common questions
Should we cooperate?+
Sometimes yes, sometimes no — and it depends on facts the client rarely has full visibility into at the start. That threshold decision is what counsel is for.
How is a parallel civil audit handled during a criminal investigation?+
With care. Statements and productions in the civil track can be used in the criminal one. The two are coordinated but never merged.
What is the timeline?+
Federal investigations move on the government's schedule, not the client's. Early representation shortens exposure and preserves options.