TAX LITIGATION/CONTROVERSY RESOLUTION

Tax audits can turn complex and challenging, often depending on the temperament and knowledge of the auditor.  Oftentimes successful resolution can only be achieve through litigation.  I have 25 years of experience litigating tax cases in the Tax Court, Federal District Court, Court of Claims, State Superior Court and Appeals to Ninth Circuit and the Court of Appeals in the Fourth District.

If you find yourself with an audit result less than favorable, contact me immediately for an evaluation of your litigation alternatives.  Oftentimes the choice of Court is critical to achieving success.  Each Court has its own set of precedents that it must follow, which may or may not, support your position.

There also important procedural differences that can be critical in achieving success.  Tax Court allow one to litigate his case without having to pay the tax until all issues are finally decided.  A potential downside is that in Tax Court is restricted to a trial before a Judge and there is some argument as to the degree of fairness these Judges exhibit.  On the other hand, if one elects to have their case decided in Federal district Court, all or a portion of the tax must be paid, but the taxpayer can request a jury trial.  My experience shows that Jurors can be much more sympathic to the unfair complexities of the Tax Code and oftentimes can relate better to the issues facing a taxpayer.

In addition, knowledge of the individual representing the IRS is oftentimes a necessary ingredient to successfully negotiating a favorable outcome.  I have extensive experience working with IRS tax professionals in Orange, Los Angeles, Riverside and San Diego counties.

Bottom-line – If you have significant tax issues with the IRS, you need an experienced tax attorney to analyze your alternatives, choose the correct Court forum and aggressively pursue your case until successful conclusion.  I’m that Attorney.  Contact me at (949) 499-1975. We are committed to providing the LA, Orange County, Riverside and San Diego county areas with legal solutions at reasonable cost.  No fee initial consultation.

Alternatively, you can email us.  We have found that oftentimes solutions to what is perceived are a major problem can be resolved relatively quickly with the right expertise.  Simply double click the button below, provide a brief description of your issues and we will provide you within 24 hours.  Our 27 years of legal experience will assure you an accurate evaluation of your situation.  Once again, there is no fee for this service.

TAX EVASION AND FRAUD

Oftentimes the IRS will target business owners and professional with criminal and civil fraud penalties as a way to make an example to other in a given community.  Being accused of Tax Evasion and/or Civil Fraud can be a disaster in terms of personal reputation as well as result in Jail and costly penalties.

If you find yourself in this position or suspect that this is were an ongoing audit is headed, you have a lot at stake.  You need an experienced veteran attorney to help walk you through these mined fields.

First rule – STOP ALL COMMUNICATIONS WITH IRS PERSONNEL.  If criminal prosecution is a possibility, you would have received the warning that “You have the right to remain silent and anything you say can be held against you”.  I’m here to tell you that in fact, everything you do say will be held against you ! What does this mean.  It means that to the extent you talk with IRS personnel, they can take the witness stand at your trial and testify as to what you said and it comes into evidence as to the facts of the case.  Hearsay is not an objection since it’s a party admission.  In rare occasions, sometimes things you never said can be held against you…this can happen when the governments case shows weakness and the IRS personnel are under pressure to win.  Don’t put yourself in this position– STOP ALL COMMUNICATIONS WITH ALL IRS PERSONNEL.

Second rule – CALL AN EXPERIENCED ATTORNEY.  The only way to protect yourself is to communicate with the IRS through a veteran Attorney who knows the intracacies of Tax Fraud litigation. I AM THAT Attorney.  Call me at (949) 499-1975.  Your conversations with the Attorney are protected by the “Attorney Client Privilege”.  This means all conversations with the Attorney are confidential.  This also means, STOP SPEAKING TO YOUR ACCOUNTANT. These conversations are not privileged.  To the extent that accounting services are required, the Attorney hires the Accountant, making the conversations with the accountant confidential and subject to the Attorney Work Product Privilege.  Ignore these caveats and the chances for a successful resolution of a fraud investigation is jeopardized.

Contact our offices at (949) 499-1975. We are committed to providing the LA, Orange County, Riverside and San Diego county areas with legal solutions at reasonable cost.  No fee initial consultation.

Alternatively, you can email us.   We have found that oftentimes solutions to what is perceived are a major problem can be resolved relatively quickly with the right expertise.  Simply double click the button below, provide a brief description of your issues and we will provide you within 24 hours.  Our 27 years of legal experience will assure you an accurate evaluation of your situation.  Once again, there is no fee for this service.