We represent clients in disputes with the Internal Revenue Service and the Texas Comptroller throughout the audit process, at the various levels of administrative appeal.

IRS AUDITS

Our tax attorneys have experience representing clients, including multinational corporations, in IRS audits involving a broad array of substantive tax issues including reasonable compensation, transfer pricing, bad debt deductions, net operating loss carry-forwards, overstatement of deductions, withholding tax, among others. 

THE IRS AUDIT PROCESS

The attorneys in our tax practice understand that representing clients in tax audits and appeals differs in significant ways from ordinary litigation. The IRS audit and appeals process may appear informal, but ultimately the IRS agent has the power of the federal government behind him or her. We are experienced handling IRS audits at the revenue agent level. Each tax attorney in the department takes a team approach, working with the client, their officers and directors, finance and accounting departments, as well as a team of professionals including the client's tax-return preparer, financial auditors and other finance advisors. Working with this team of professionals, we coordinate timely, well-documented responses to the IRS.

OUR APPROACH TO AN IRS AUDIT

Based on our experience in tax controversy and general tax planning, we try to anticipate the next areas of inquiry from the IRS. Each attorney in our tax practice understands that IRS audits can often become protracted, time consuming matters that if not handled properly can be disruptive to business operations. We manage the IRS audit process to enable our client to keep focus on running their business.

Our attorneys help the client assess risk and plan responses to anticipated lines of questions from the IRS. We believe that being prompt, courteous, and responsive to the IRS shows good faith and is generally more likely to result in an acceptable outcome than taking a combative, adversarial approach. However, despite the professional cordiality, we are firm and resolved in defending our client's interests.

IRS APPEALS

We represent clients at the IRS Appeals level in negotiations with the Appeals Officer and by preparing written protests to the revenue agent's proposed assessments. Our tax attorneys help clients dealing with ancillary issues related to a tax dispute, such as financial statement disclosure, tax reserve provisions, and tax return treatment of disputed issues going forward.

CONTACT US

To speak to a tax attorney about an inquiry or audit notice from the IRS, please contact us here, or call us at 713.650.9700.

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