Tax Litigation

Although most tax disputes with the IRS and the state tax authorities are resolved by agreement or an administrative settlement, sometimes the only way to vindicate your position is to go to court. The dollar value of the issue may be too large for the taxpayer to settle, there may be irresolvable disputes about the facts, or the parties may simply have different views of what the applicable law means.

Whether your case is yet to be filed or ripe for appeal, San Diego Tax Law Group attorney can translate the firm’s substantive¬†knowledge and courtroom experience into a winning tax litigation strategy. San Diego Tax Law Group can defend your rights in all types of tax controversies from individual tax liability and collection disputes to the business tax deficiency and refund litigation.

Always considerate of the litigation costs, we endeavor to work with the client to identify the issues that are likely to be critical to the litigation. We focus our efforts on those key issues often beginning while the audit is still underway, so that we are in a position to push for the most favorable pre-trial settlement or to present the strongest case at trial. Our goal is to present your tax controversy to the court and the opposing tax authority with the facts and the law in the most persuasive light.

San Diego Tax Law Group attorney can guide you through the audit and litigation process with strategic advice and effective legal representation at all of the following stages:

  • Dealing with the IRS Examiners;
  • Responding to information requests or summonses;
  • Requesting technical advice from the IRS National Office;
  • Negotiating closing agreements and other settlements;
  • Preparing protests and negotiating settlements in the IRS Appeals Office;
  • Preparing and filing your U.S. Tax Court Petition;
  • Choosing the strategy for your tax litigation;
  • Conducting discovery;
  • Litigating your case at U.S. Tax Court.

Substantive and procedural tax law knowledge and effective representation are crucial to the success of your case at court. Consult San Diego Tax Law Group regarding your options and the most efficient tax litigation strategy.