Tax Controversies and Litigation
The experienced attorneys of our firm represent clients in trial and appellate litigation, regularly appearing before the United States Tax Court, United States Bankruptcy Court, United States Federal Claims Court, various United States District Courts, and the United States Court of Appeals for the Ninth Circuit. In representation of both criminal and civil cases, numerous decisions have published by our team of competent tax litigators.
Some representative unreported cases:
- Hundreds (if not thousands) of miscellaneous civil tax cases in the Tax Court, the United States District Court and the Claims Court which have resulted in unreported decisions or judgments have been settled;
- Representation in federal and state tax audits, including audits involving both civil adjustments and the potential for civil and criminal assessments and penalties that have been resolved short of a reported decision;
- Closing agreements;
- Letter Rulings;
- Numerous litigation regarding claims for refund.
Our clients are varied and include large corporations, business entities, estates, trusts, individuals and nonprofit organizations. With any tax problem, our foremost objective is to resolve the controversy early without legal proceedings using our advanced understanding of the nuances of tax concepts and precedent. If it is in the best interest of the client, we will litigate the tax controversy navigating court procedures with effective trial strategies.
In addition, litigation or legal proceedings are a strategy used to resolve tax controversy. The Law Offices of Stephen Moskowitz, LLP is a tax law firm that provides both federal and state tax litigation representation. The tax attorneys of our firm possess extensive experience in all facets of tax controversy and have advised and represented both U.S. and foreign taxpayers nationwide.
Our tax attorneys have a comprehensive understanding of the full spectrum of all areas of tax including:
- audits and appeals
- payroll and sales tax controversy with the Franchise Tax Board
- estate and gift
- unfiled or fraudulent returns
- foreign bank accounts or offshore banking issues.
Many of our tax litigation cases are handled on a flat fee basis for our clients to know at the outset of the case the cost involved. We look forward to advising or representing you in the area of tax litigation.