IRS Tax Relief Attorney Johns Creek

IRS Tax Relief Attorney Johns Creek
Resolving IRS Administrative Controversies
Pre-controversy advice and counsel.  Our tax attorneys combine litigation and substantive tax experience to assist clients in effectively anticipating and planning for future controversies.  Often, when the tax treatment of an item or transaction is challenged, the ultimate resolution is influenced significantly by actions taken or not taken when the transaction was planned, implemented, or first reported.  With this in mind, we provide experience-based advice on reporting, disclosure, document retention, and other pre-controversy matters.
Audit controversy skills.  We effectively use all available procedural techniques, including pre-filing agreements (PFAs), requests for technical advice, Fast Track Appeals resolution, Early Referral, and other IRS practices and programs.  We have extensive experience with IRS summonses, enforcement proceedings, and joint defense agreements.
Individual and coordinated IRS and Treasury settlement efforts.  We fashion creative and effective approaches to settlement.  Our experience encompasses not only direct negotiations for single clients, but also group representations of taxpayers with the same or similar issues.  We work hard to achieve favorable results, identifying the most effective approach, whether it be with the examining agent, LB&I, OTSA, Chief Counsel, the Office of the Commissioner, Treasury, or elsewhere.
IRS Appeals controversies.  We prepare protests and negotiate with IRS Appeals to achieve favorable settlement results, and routinely appear before Appeals offices across the country, using all available Appeals tactics and strategies, including early referral and Post Appeals Mediation, either to achieve settlement or to position the case to proceed most effectively into litigation.
Deep and Current Trial and Appellate Experience 
Choice of forum.  We have a wealth of knowledge on which to base critical decisions regarding choice of forum for litigation.  Our backgrounds and experience enable us to identify both substantive and procedural benefits and detriments that bear on choice of forum decisions.
Settlement of cases in litigation.  Many cases, when not settled administratively, can be favorably settled in litigation with the Justice Department or IRS.  We have a history of achieving such settlements, drawing on our litigation skills and our experience as former Justice Department litigators and judicial clerks.
Actual trial experience.  Relying on our courtroom experience, we develop and implement efficient, effective, and thorough trial strategies.  Whether the case is presented by dispositive motion, or by trial, we have the required skill and experience, including handling intricate discovery and evidentiary disputes, the preparation and examination of fact and expert witnesses, and utilization of the most sophisticated electronic trial presentation and briefing techniques.  Our experience enables us to be prepared for all the twists, turns, and surprises of trial advocacy.
Effective appellate advocacy.  Our tax attorneys have argued cases in every major federal Court of Appeals, as well as before the US Supreme Court.  Our brief writing and appellate advocacy skills are recognized as leading in the bar.
IRS Tax Relief Attorney Johns Creek