we will do it together

Tax Controversy and Litigation

Tax Controversy & Litigation Lawyer Orlando

At ALG, we are deeply committed to delivering unparalleled guidance to corporations, partnerships, and individuals entangled in complex tax disputes. We specialize in dealing with the Tax Division of the U.S. Department of Justice, the Internal Revenue Service, and state and local tax authorities. 

What elevates our practice above others is more than just our profound grasp of the Internal Revenue Code’s complexities. We have extensive experience navigating tax controversy proceedings, adeptness in liaising with taxing authorities, and consistently successfully and efficiently resolving tax matters. This unique blend of skills and knowledge sets us apart and underpins our reputation for excellence. Our clientele is as varied as it is prestigious, encompassing diplomats, multinational corporations, high-net-worth individuals, and nonprofits.


From the initial audit through negotiations and litigation, we’re here to advocate on your behalf and ensure you’re not being taken advantage of. Don’t hesitate to reach out if you need representation in a tax controversy. Whether you’ve just received a hefty demand from a tax collector, are neck-deep in the audit process, or are preparing for litigation, we’re here to step in.

Key Services

Orlando high rise black and white

What is Tax Controversy and Litigation?

 

Tax controversies are legal disputes involving taxpayers, such as individuals and businesses, and tax agencies, like the IRS. They can include disputes about tax liabilities and refund entitlements, among other things. 

 

Tax litigation can be civil or criminal. Civil cases typically begin with an IRS audit (usually conducted by mail), where the tax agencies determine whether taxpayers have been paid the right amount. Taxpayers can challenge IRS findings, including protesting to the U.S. Tax Court.

What might begin as a standard civil audit can transition to a criminal investigation if evidence of tax evasion or fraud is discovered. Criminal cases involve the IRS’s criminal investigation branch (IRS: CI). Before a criminal case is formally initiated, a grand jury will decide whether to indict the accused based on the evidence from the investigation. 

 

Given the often high stakes of tax litigation, it’s always in your best interest to consult an experienced attorney. Professional expertise goes a long way in preparing your case and successfully resolving tax controversies.

 

Our Key Services

 

Pre-Controversy Tax Advice

We take a proactive approach to tax controversies, aiming to minimize the risk of disputes before they occur. We offer meticulous review of tax returns and financial documents to spot problems before tax authorities. We will also help your business develop a comprehensive compliance policy to ensure your business has the practice in place to respond to an IRS audit efficiently.

 

Tax Audits

We represent clients through every stage of IRS and state agency audit processes. We’ll handle all the essential documentation and skillfully negotiate with agencies to resolve your dispute efficiently. From designing corporate compliance processes to maintaining accurate records to vigorously representing your case throughout litigation, ALG has you covered.

 

Administrative Appeals

If you disagree with a tax agency’s findings, we’ll file your appeal and argue your case in any administrative procedure. Our experts have extensive experience with administrative appeals and know the common errors the IRS makes during the audit process. Let us be your voice when the IRS is trying to take more than you owe.

 

Alternative Dispute Resolution (ADR)

We facilitate dialogue between taxpayers and tax authorities, developing creative and agreeable solutions. We aim to protect our client’s interests every step of the way, including saving you unnecessary expenses where possible. If avoiding lengthy litigation is possible, we’ll do everything we can. If not, we’re adept in litigation and will vigorously protect your rights.

 

Freedom of Information Act (FOIA) Requests and Actions

Our team assists in obtaining necessary tax agency documents through FOIA requests. We manage the entire process, from preparation to litigation in federal courts if necessary. We also handle appeals for denied or partially denied requests.

 

Summons Enforcement Actions

We’ll challenge the validity and scope of IRS summonses, negotiate document production and testimony limitations, and protect our clients’ privacy interests. We have experienced challenging the IRS’ noncompliance with formal summons requirements in front of the District Court and know the ins and outs of the summons procedure. Put simply, we’ll make sure the IRS plays by the rules before you’re forced to turn over extensive documentation.

 

Representation of Taxpayers Under Criminal Investigation

We provide critical advice on rights during criminal tax investigations. We’ll liaise with law enforcement agencies to negotiate plea agreements. If necessary, we are always prepared to represent your interests at trial.

 

Civil and Criminal Tax Litigation

Our litigation team represents clients in civil and criminal tax cases across various courts, including the U.S. Tax Court, Federal District Courts, and state courts. We handle everything from the preparation and filing of legal briefs to the presentation of oral arguments.

 

Appellate Advocacy

We offer specialized appellate advocacy in the U.S. Court of Appeals, the U.S. Supreme Court, and state courts. Our services include preparing appellate briefs, oral argumentation, complex legal issue analysis, and ensuring compliance with critical procedural rules.

Through each of these services, we aim to navigate the complexities of tax law effectively and achieve the best possible outcomes for our clients, safeguarding their financial and legal interests at every turn.

 

Understanding the IRS Audit Process

For many taxpayers, the IRS audit process can be confusing and uncertain. Understanding how this process works and knowing how to prepare can make it easier and reduce the stress you feel when the IRS comes knocking.

The IRS audit process starts with reviewing taxpayers’ financial information, like bank accounts and tax returns, to ensure their income is accurately reported. Audits can take many forms, like correspondence (mail), office, or field audits in a taxpayer’s home or business. How the audit is conducted is up to the IRS. They will typically choose their audit style based on the situation’s complexity and how much money is involved.

Knowing what can trigger an IRS audit can help you avoid one in the first place. Some common triggers include:

  • Discrepancies between reported income and income include on w-2s or 1099s
  • Reporting high incomes or large deductions
  • Participation in large cash transactions
  • Home office deductions
  • International transactions

Knowing how to prepare is vital if you or your business is facing an IRS audit. In all cases, the best preparation comes from planning before the IRS begins its audit. Some proactive steps you can take to stay prepared for an audit include:

 

    • Stay Organized: Keep all financial documentation organized and readily available. This includes all documentation of deductions and credits you claimed on your tax returns.
    • Be Knowledgeable: Understand the information you include on your tax returns. If you used a tax preparer, have them review the audit notice and assist in preparation.
    • Know Your Rights: The IRS must respect your legal rights. Knowing what rights you have will make sure they don’t overstep.
    • Leave it to the Professionals: Consider hiring a tax professional who has handled audits before. An experienced tax attorney can provide valuable guidance throughout the audit process.

Preparing for the IRS audit process makes it more manageable and less intimidating. By keeping accurate records and understanding what may trigger an audit, taxpayers can avoid it altogether or set themselves up for the best possible outcome.

Tax Controversy and Litigation

Strategies for Successful Tax Dispute Resolution

The first step in managing tax disputes is to gather and organize all relevant documentation. A tax professional can analyze legal issues and coordinate with tax authorities on your behalf. Alternative dispute resolution methods, such as mediation or arbitration, can frequently offer a cost-effective solution. However, be advised that deals are only sometimes reached in these mediations. Therefore, having an attorney who is ready and willing to take your case through litigation is crucial.

 

The Role of Technology in Tax Litigation

Technology has transformed tax litigation. Electronic discovery tools efficiently manage vast volumes of data. Data analytics reveal trends and patterns important for protecting against and preventing tax controversies. Modern developments in artificial intelligence have already proven valuable, as they can assist in every stage of the preparation and litigation process. With artificial intelligence evolving rapidly, more advancements in the field of tax controversy are assuredly coming. 

 

International Tax Controversies: Navigating the Global Landscape

International tax controversies involve the interplay between domestic and international tax laws, treaties, and principles. Because of the advanced understanding of international laws required to manage these controversies, you need a professional up to date with global tax practices. ALG provides expert tax advising services for foreign business owners operating in the United States and Domestic business owners outside the United States. We will ensure compliance and accurate reporting of all international tax requirements.

 

Preventive Strategies to Avoid Tax Disputes

Compliance policies, conducting regular internal audits, and staying updated with tax laws are the best ways to avoid disputes. Make sure to keep accurate records of all business transactions and write-offs. If you need clarification on whether your tax filings are correct or need general tax advice, having a reputable tax attorney on hand is essential to help keep you out of hot water with the IRS. When it comes to tax audits, defense is the best offense. 

 

The Future of Tax Controversy and Litigation

The future of tax controversy and litigation will likely see an increased focus on international tax enforcement, the challenges of digital taxation, and greater scrutiny of digital payment transactions. A recent example is the IRS’ post-pandemic crackdown on peer-to-peer payment platforms like Venmo and Cash App. As businesses transform and digitalize, expect tax codes to evolve accordingly. 

 

How Our Tax Attorneys Can Help You

Our firm provides comprehensive tax litigation and controversy support, from preemptive tax planning and audit defense to arbitration and litigation. Whether you’re facing an IRS audit, dealing with complex international tax issues, or navigating appellate courts, Aventus Law Group is here to help. Our commitment to personalized service ensures that you receive the expert guidance you need when you need it most.

Schedule Your Consultation Today

Schedule a consultation with our Orlando business lawyers today. We offer flexible consultation options to accommodate your busy schedule.

Be sure to get the legal support your business needs. Contact Aventus Law Group to discover how our team can help you achieve your business goals. Please feel free to contact us to schedule a consultation at info@aventuslawgroup.com or 321-250-3577.

Schedule a Consultation with a Florida Business and Corporate Law Attorney

From our offices in Orlando, Miami, The Villages, and Atlanta, Aventus Law Group provides services to local governments, individuals, and businesses throughout the states of Florida and Georgia. We invite you to call us at 321-499-9551 or use our online contact form to request additional information or schedule a consultation about our appellate legal services.