Tax Court Litigation and Defense
Work With Attorneys Who Have Proven Results in Tax Court Litigation & Defense
Filing of briefs.
Negotiations with the IRS.
Who has time for all of that? You surely don’t.
More importantly, if you are facing tax charges, you need an experienced tax attorney on your side. You simply don’t know what you don’t know, and that can lead to immense problems down the road if you try to resolve your IRS tax litigation on your own.
Put Silver Tax Group On Your Side
Before filing an appeal in tax court on your own and running into issues, consider reaching out to the experienced tax defense lawyers at Silver Tax Group. We have the expertise you need to protect your rights. We handle litigation involving any and all IRS tax disputes.
WHEN YOU HIRE US, WE CAN HELP YOU:
Already filed yourself?
It’s not too late. We can work to have your case removed from tax court, so we can negotiate with the IRS on your behalf. Our team of attorneys has a proven track record of obtaining the best possible outcomes for our clients throughout the United States.
Facing criminal charges?
We are still the firm for you if your case has escalated to criminal charges. Learn more about our criminal tax defense services.
Don't Try Navigating The Tax Court System On Your Own
You are almost certain to fail if you venture into this maze on your own. We can make sure everything is handled timely and properly, providing you with peace of mind every step along the way. Contact us today to schedule your free case evaluation with an experienced tax defense lawyer.
Why You Need an IRS Defense Attorney Instead of Negotiating Yourself
3,395 tax cases were opened in 2016, and 2,672 resulted in convictions.
Many people fear going up against the Internal Revenue Service (IRS), and rightly so! With the constantly evolving nature of tax law, it can be hard for ordinary citizens to keep abreast.
Therefore, it is no surprise that confusion sets in once you receive a notice from the IRS.
When facing a legal tax issue, you need to turn to a tax attorney. Unless you know tax law and can understand what the implications are for your case, you need someone who ‘speaks the language.’
Are you wondering if you need a tax counsel? Here are some situations that call for you to get some legal tax help.
When You Need Attorney-Client Privilege
Doing your taxes can be a trying experience for many people. For some, there might be legal matters which aren’t as clear cut. As a result, they might wonder or fear that they may be exposed to some legal backlash.
When you hire a CPA or a tax preparer you need to keep in mind that any information you share with them is not safe. Should your tax matter end up in a trial then the court can compel your tax preparer or CPA to give evidence against you.
On the contrary, any secrets that you confide in your tax counsel will not be used against you in case you end up in a trial. The IRS can hardly make your lawyer present documents, let alone act as a witness against you.
The attorney-client privilege concept was created so that clients in both criminal and civil cases could be completely honest with their lawyer.
It is important to note that there exists a statutory ‘tax preparation’ privilege. This was added to the tax code in 1998 via the IRC Section 7525(a)(1) amendment.
Despite this fact, the privilege is rather narrow and does not apply to criminal tax cases. On the other hand, the attorney-client privilege does apply to criminal tax cases. It also does provide several protections under the law that can help you.
If you know or suspect your tax matter involves some incriminating issues then a tax lawyer is your best bet.
When the IRS Decides to Audit You
Few things strike fear into the hearts of people than a notice for an IRS audit. An audit is a means through which the IRS seeks to confirm that the information you have given on your returns is complete and accurate.
There are many reasons why the IRS conducts audits. Generally speaking, the IRS can audit your returns for the past three years. If you happen to be in the wrong, you can get penalties that are as high as 20% of the ‘erroneous amount’.
When the IRS decides to audit you, they will send you a notice via the U.S. postal service. The first thing you should do when you receive such a notice is to consult a tax counsel.
Many people make the mistake of hiring a CPA. While they are familiar with the tax code, they may not have experience in defending people who are staring down an audit.
A tax counsel is vital during an audit because they can tell if an auditor is digging deeper into your returns to look for criminal intent.
In such cases realizing this as soon as possible will help you begin preparing adequately for potential criminal charges.
When you have a tax counsel they can negotiate on your behalf with the auditor for you to pay less than you owe. The IRS will allow you to do this through an Offer-in-Compromise (OIC).
You will need to convince the IRS on a few things to get an IOC. Your tax counsel will have to prove you are unable to pay your tax liability in full or in installments.
They will also have to prove that there is a doubt as to the amount you owe the IRS.
When You Receive a CP Notice from the IRS
The IRS from time to time will send out a CP notice to taxpayers. These notices are usually to alert you of a discrepancy within your tax filing that needs resolving. They can include:
● A change in your tax responsibility due to a grant you received for a first time home purchase
● When the IRS owes you a refund that you most likely didn’t expect
● If the IRS is reviewing the information on your returns
● When you need to provide more information regarding your tax returns
● If the IRS can’t process your returns due to some incorrect information
Regardless of the reason, you need to talk to a tax counsel whenever you get a CP notice. A tax counsel has the experience necessary to help you know what the implication of the notice is for you.
When You Need Someone to Speak on Your Behalf to the IRS
There are times where you may need to have someone represent you when speaking to the IRS. A tax counsel is a perfect choice for you in such situations.
If you decide that this is the route you want to take, the first thing to do is give them a power of attorney. Doing this gives them the legal authority to speak on your behalf.
A tax counsel can help filter what you want to say to the IRS so that it is in the best possible light.
By nature, ordinary citizens will share everything with the IRS. However, many times this inadvertently ends up working against you. Your counsel will know what to say and how to best say it so that they protect you where necessary.
Another reason why you need to let a tax counsel speak on your behalf is that they understand the legal rights you have as a taxpayer.
For example, the IRS will say that it must speak with you directly. There is no law that requires you to meet the IRS in person when you sign over power of attorney.
The IRS’ internal manual instructs officers to try their best to meet with you, but that is about it.
If you do not have a tax counsel representing you, you would likely not be aware of this. As a result, you would end up meeting with the IRS and potentially making your case worse.
A tax counsel, on the other hand, has in-depth knowledge of all your rights and will guide you to protect your interests.
Get the Right Representation
Just because you find yourself facing a legal tax matter doesn’t mean you should panic. Instead, you need to call a tax attorney who will guide you through the process.
If you are tempted to represent yourself, remember that there are many strategies the IRS can use that you might not be aware of. A tax counsel has the years of experience necessary to spar with the IRS on your behalf.
Would you like to talk to an experienced tax counsel?
Silver Tax Group is ready to answer your call. Contact us today for a free case evaluation and a chance to resolve your issue.
Litigation? You Can Fight The IRS in Tax Court And Win. Our Attorneys Can Help.
No matter where you are in the process, we can help you make the best of your situation.