Tax Controversy and Litigation
Basswood Counsel represents companies and individuals at every level of resolving disputes with the Internal Revenue Service (IRS), from meeting with examiners to tax appeals, and if necessary, in tax litigation. We utilize our tax knowledge and practical approach to review the client’s tax returns and back up documentation to initially determine the client’s position as it relates to the audit or inquiry, look for other deductions or tax savings that may not have initially been taken on the tax return, and then develop a strategic strategy to approach and respond to the IRS.
Our tax lawyers combine deep technical tax knowledge with rich experience in dealing with the IRS. Our detailed knowledge and experience will enhance the odds of a favorable result at the audit level. We carefully advise our clients on and respond to information document requests (IDR). The IDR process can seem as simple as just answering a few questions, but carelessly drafted IDR responses often lead to the expansion of the scope of the audit. Our team thinks through the IDR requests in light of the client’s circumstances including documents filed with the IRS, to craft detailed and appropriate responses in order to avoid additional complications.
Basswood Counsel has experience representing clients before the IRS Office of Appeals. Appeals proceedings are more cost effective, faster, and less distracting for the taxpayer than tax litigation. In addition, unlike litigation, the taxpayer’s privacy remains strongly protected. Appeals proceedings are not trials, but assembling the type of evidence that would win in trial is the key to obtaining concessions and strong settlements. Our written protests, and the legal research behind them, have persuaded Appeals officers to concede the IRS’ position in our client’s favor. We have experience working with Appeals officers and providing appropriate responses to their questions in order to receive a favorable result for our client.