August 2016

Federal Civil Tax Controversies


Our tax attorneys represent taxpayers in all phases of federal civil tax controversies. During IRS audits, we deal directly with IRS agents and also work behind the scenes to strategize with other professionals who may be interfacing with agents. If a matter is not resolved at the audit level, we handle administrative appeals with the IRS to obtain highly favorable settlements—and many times full IRS concessions—for our clients. Where matters still cannot be resolved through administrative appeals, Sideman’s tax attorneys represent clients in litigation in the United States Tax Court, federal district courts and the Court of Federal Claims, all of which hear federal tax disputes. When warranted, we handle appeals of tax cases in the Ninth Circuit Court of Appeals as well as other appellate courts and the U.S. Supreme Court.

For clients addressing collection disputes with the IRS, we negotiate suspension of collection actions, installment agreements and offers in compromise. We address problems with liens and levies and wrongful collection actions as well as more serious jeopardy assessments, which we have successfully defeated. We also handle collection due process and equivalent hearings and associated litigation. In addition, we represent clients with innocent spouse claims.

Our tax attorneys handle all types of federal civil tax disputes, including income, employment, estate and gift taxes, and partnership proceedings. We have been active in representing clients in listed and reportable transaction (tax shelter) cases. We also handle preparer penalty and other penalty cases, including civil fraud penalties. In employment cases, we represent clients in responsible person or trust fund penalty matters. We have extensive experience with disputes over interest, including interest suspension and abatement issues. We also represent clients in summons enforcement matters and have resolved numerous cases involving foreign bank account reporting issues.