The Internal Revenue Service (IRS) is the only federal agency with which virtually every individual and business interacts. Those dealings may result in controversies of various kinds, including audits, penalty disputes, summons proceedings, lien and levy matters, employment tax disputes, and “innocent spouse” claims. In more serious cases, the IRS may initiate a criminal investigation, or a criminal investigation of another issue may expand to include potential criminal tax violations.
Zuckerman Spaeder LLP’s tax attorneys have a thorough understanding of IRS procedure, a working knowledge of substantive tax areas, and the skill to advocate a position before the IRS or, if necessary, in court. Our tax litigation team, which includes a former assistant attorney general of the Tax Division of the Department of Justice, has tried cases to verdict in a number of U.S. district courts throughout the country, in the U.S. Tax Court, and in state courts. They have also briefed and argued cases in several U.S. Courts of Appeal.
Where a client is the subject of multiple parallel proceedings involving both criminal and civil tax issues, understanding the relationship among the various divisions of the IRS, the U.S. Attorneys' Offices, and the Department of Justice is crucial. Daily monitoring of developments in the Service's enforcement priorities and litigating positions and regular participation in professional organizations provide up-to-date knowledge of the field, and the ability to communicate with government representatives at all levels.
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