our Services

Tax Advocacy and Dispute Resolution Services

From cross-border filings to state-level challenges and IRS scrutiny of tax credits, we bring clarity and strategy to help you navigate audits, appeals, and dispute resolutions with confidence.

Expert Guidance for Tax Audits & Disputes

When you're facing a federal, state, or local tax dispute, the stakes are high—and the path forward isn’t always clear. Missteps can lead to costly penalties and long-term consequences for your business. A sophisticated, strategic approach guided by technical precision is key to successfully approaching tax disputes. 

With IRS enforcement resources increasingly concentrated on high-impact issues—and state agencies stepping up scrutiny to close revenue gaps—tax controversy is becoming more targeted, technical, and complex.

With years of experience resolving tax controversies for corporations, partnerships, and individuals at the federal, state and local levels, we bring a detailed understanding of how these processes work and the expertise required to navigate this complexity. Whether you're preparing for an audit or appeal, needing to get penalties abated, or trying to get on a payment plan, we help you stay in control at every step.

The Shifting Tax Enforcement Landscape

With reduced IRS staffing and rising state-level enforcement, audits are becoming more selective—and more focused on areas with a high potential return. International reporting, multistate nexus, and high-dollar credit claims are among the top targets. Businesses need to be ready with defensible positions and documentation from day one.

Decisive Support for High-Stakes Tax Matters

I’ve worked directly with clients under audit, in examination, and navigating disputes at the federal, state, and local levels. These cases often involve intricate issues and high stakes, demanding a nuanced, considered approach.

That experience shapes how I work today: with a calm, strategic approach that helps clients understand the process, protect their position, and resolve issues efficiently.

End-to-End Support for High-Impact Tax Controversy Matters

Tax controversy rarely begins and ends with a notice. Whether you’re responding to an IRS audit, navigating state-level scrutiny, or preparing for an administrative appeal, we help you take control early—and stay proactive throughout the process.

We support clients through the full lifecycle of tax advocacy, with experience across international reporting, multistate nexus, credits and incentives, and more. From shaping your technical position to managing examiner interactions, we help you stay focused, compliant, and well-positioned for resolution.

Audit & Appeals Representation

Tax examinations require more than just compliance—they demand careful strategy, disciplined communication, and sound judgment at every step. We represent clients through all stages of federal, state, and local audits and administrative appeals, helping manage both the process and the risks.

Strategic Response Management

We assist with IDRs, interviews, and site walkthroughs—ensuring responses are thorough but not excessive, protecting your position without creating new exposure.

Federal, State & Local Representation

We represent clients in audits and appeals involving the IRS, state tax authorities, and local jurisdictions across a range of issue types and industries.

Technical Issue Framing

We help develop and refine tax positions that are well-supported and responsive, often preparing memoranda or supporting documentation used in both audit and appeals settings.

Appeals-Level Support

At the appeals stage, we guide clients through the preparation of position papers and assist with negotiation strategies to improve outcomes.

Coordination with In-House Counsel

When needed, we collaborate with internal legal teams to align on positions and prepare for higher-stakes proceedings.

With focused representation and experienced judgment, we help clients manage uncertainty, maintain compliance, and achieve resolutions that stand up to scrutiny. As agencies increasingly turn their focus toward technically complex, documentation-heavy cases, successful outcomes increasingly depend on a robust understanding of both the rules, and the enforcement mindset behind them.

Pre-Audit Readiness Assessments

The best way to win an audit is to start preparing well before it starts. We help clients identify areas of exposure and take proactive steps to address them—minimizing surprises and reducing risk.

  • Exposure Identification: We review past filings and supporting documentation, identify high-risk areas, and help quantify potential liabilities, conducting documentation reviews to ensure your records are complete and defensible.

  • Mitigation Strategies: We offer practical steps to address gaps, remediate risks, and strengthen your audit posture.

Take a proactive approach: these assessments equip you with clarity and control before tax authorities get involved, helping you identify and address exposures before they become an issue.

Penalty Abatements & Other Waiver Requests

When penalties hit, we help businesses push back. We prepare and submit abatement requests that are grounded in both technical merits and procedural precedent.

Reasonable Cause Submissions

We draft persuasive narratives supported by facts, tax authority guidance, and relevant legal standards.

First-Time Penalty Abatement

We help determine eligibility and pursue relief for clients with a clean compliance history.

Other Waivers

We help apply for other applicable waivers at the federal and state level that affect tax liabilities.

Follow-Up Support

We assist with appeals or additional documentation if initial requests are denied.

 

Our deep experience applying penalty relief rules has helped clients secure significant penalty reductions and avoid unnecessary financial strain—even in high-stakes cases.

Late Election Relief & Private Letter Rulings

Missed election filings and uncertainty are inevitable in a complex tax environment. When they happen, strategic advocacy can preserve intended outcomes and protect against unnecessary risk. We help clients correct procedural missteps and obtain clarity on uncertain tax positions.

  • Late Election Relief Submissions: We prepare and submit requests to fix missed tax elections—including S corporation elections, QSub elections, entity classification elections, and more—helping businesses preserve valuable tax treatments.

  • Private Letter Ruling (PLR) Requests: When tax guidance is unclear or unavailable or when procedures require a letter ruling due to the need for tax authority consent, we guide clients through the PLR process, including pre-submission conferences with IRS subject matter experts to strengthen requests and improve outcomes.

With a clear, experienced approach, we help clients navigate the procedural side of tax law—protecting tax positions, unlocking opportunities, and mitigating future risk.

Installment Plans & Offers in Compromise

When paying in full isn’t an option, our professionals can help negotiate payment arrangements that protect both your business and your balance sheet.

  • Eligibility Evaluation: We assess your financial situation and recommend the best path forward based on IRS or state criteria.

  • Installment Agreement Submissions: We prepare and file structured payment plan proposals that align with your cash flow and compliance goals.

  • Offer in Compromise (OIC) Guidance: Get support preparing strong OIC applications that demonstrate inability to pay and meet IRS and state tax authority standards.

With the right plan in place, you can resolve outstanding tax debt while maintaining operational stability.

Delinquent International Filing Submissions

Late or missing international information returns can lead to significant penalties. We help clients get back into compliance, quickly and strategically.

  • International Information Reporting for Businesses: We assist with accurate preparation and filing of Forms 5471, 5472, 8865, and related disclosures—ensuring compliance with U.S. reporting requirements involving cross-border issues and reporting, such as forms for foreign entities and partnerships.

  • Offshore Disclosure for Individuals: We support individuals navigating Streamlined Domestic and Foreign Offshore Procedures, helping reduce penalties while bringing foreign asset and trust reporting into full compliance.

  • Amnesty Program Eligibility: Determine whether you qualify for the Streamlined Filing Compliance Procedures or other IRS relief programs.

  • Reasonable Cause Letters: We craft effective explanations that support penalty abatement requests for late or missed filings.

We help reduce exposure, avoid unnecessary penalties, and restore full compliance with confidence.

Controversy Touchpoints Across the Tax Spectrum

Tax disputes often originate from complex specialty areas. We provide controversy support rooted in our deep expertise across international, state and local, and incentive-based planning.

  • International Tax: Respond to audits involving cross-border issues and reporting, such as Forms 3520/5471/5472/8865, GILTI/Subpart F exposure, transfer pricing, and foreign tax credit claims.

  • State & Local Tax (SALT): Manage nexus disputes, apportionment challenges, and issues tied to credits and incentives across multiple jurisdictions.

  • Credits & Incentives: Support IRS and state reviews of R&D credits, Employee Retention Credit (ERC) claims, and other incentive-based filings.

  • Entity Structure, Taxable Presence, and Income Sourcing: Defend technical positions related to taxable presence, entity structure and classification, and income sourcing.

These matters often require coordination between technical tax expertise and audit strategy, and are among the most likely to trigger scrutiny under today’s audit priorities. Our cross-specialty knowledge allows us to support stronger outcomes at every level of representation.

Schedule a Consultation

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