Practice Areas

IRS REPRESENTATION

At PKDB, our IRS Tax Controversy Representation practice area is dedicated to defending and supporting clients through every phase of a tax controversy, from audits to appeals, tax court litigation, offers in compromise, penalty abatement, and voluntary compliance initiatives. Our team of seasoned tax attorneys brings a depth of knowledge and experience in dealing with the IRS, providing strategic advice and vigorous representation to both individuals and businesses facing challenging tax disputes. Understanding the stress and potential financial implications these issues can carry, we commit ourselves to navigate the complexities of tax law on behalf of our clients, aiming to resolve disputes efficiently and effectively. By leveraging our expertise in tax negotiation and litigation, we strive to achieve favorable outcomes, whether that means minimizing liabilities, negotiating settlements, or contesting unjust penalties.

The approach at PKDB is comprehensive and client-focused, recognizing that each tax controversy is unique and requires a personalized strategy. We work closely with our clients to understand their specific situation, meticulously preparing for audits, crafting compelling appeals, and, when necessary, representing clients with tenacity before the tax court. Our services also extend to proactive measures such as negotiating offers in compromise to settle tax debts for less than the full amount owed and pursuing penalty abatement to relieve clients from penalties stemming from circumstances beyond their control. Moreover, we assist clients in taking advantage of voluntary compliance programs to correct past tax issues before they escalate. Choosing PKDB means enlisting a team that is not only adept at managing the intricacies of IRS policies and procedures but is also committed to safeguarding your rights and financial well-being throughout the tax controversy process.

At PKDB, our IRS Representation practice area specializes in guiding individuals and businesses through the complexities of dealing with the Internal Revenue Service (IRS), offering expert counsel and robust defense in matters ranging from audits to litigation. Our seasoned tax attorneys possess a profound understanding of tax laws and IRS procedures, ensuring that our clients navigate their legal challenges with confidence. Whether facing an income tax audit, disputing transfer taxes, or needing representation in tax litigation, our goal is to provide strategic solutions that minimize liabilities and protect our clients' financial interests. We are committed to offering clear, effective communication with the IRS on behalf of our clients, diligently working to resolve disputes efficiently and favorably.

FBAR (Foreign Bank and Financial Accounts Report): A requirement for U.S. persons to report foreign financial accounts exceeding certain thresholds to the IRS, aiming to prevent tax evasion. Our firm assists clients in compliance and in resolving disputes related to FBAR filings.

ERC Audit (Employee Retention Credit Audit): Reviews by the IRS to verify the eligibility and accuracy of claims made under the Employee Retention Credit program, designed to encourage businesses to keep employees on the payroll during COVID-19. We provide guidance and representation to ensure that clients’ ERC claims are substantiated and defended against any challenges.

Income Tax Audit: An examination of an individual's or corporation's tax returns by the IRS to verify accuracy and compliance with tax laws. Our attorneys are skilled in managing the audit process, defending clients' tax positions, and negotiating with the IRS to resolve any discrepancies.

Transfer Tax Audit: Involves the IRS reviewing transactions subject to estate, gift, or generation-skipping transfer taxes to ensure proper reporting and tax payment. We represent estates and individuals in minimizing their transfer tax liabilities and contesting audit findings. Litigation: Refers to the process of resolving tax disputes with the IRS in court. Our firm offers experienced litigation representation, advocating fiercely for our clients’ rights in tax controversies. Contest: The act of disputing IRS findings or charges, whether through administrative processes or in court. We assist clients in contesting IRS decisions, employing strategic defenses to challenge the IRS's position. CDP (Collection Due Process): A legal procedure allowing taxpayers to appeal IRS collection actions, such as levies or liens. Our team guides clients through the CDP hearing process, advocating for their rights and seeking the best possible outcomes.

At PKDB, we understand the stress and uncertainty that tax issues can cause. Our IRS Representation practice is here to lift that burden, offering seasoned legal expertise to navigate the maze of IRS regulations and procedures. With a focus on proactive solutions and vigorous defense, our firm stands as a steadfast ally to taxpayers facing IRS challenges.

Furthermore, PKDB excels in negotiating Offers in Compromise and setting up payment plans with the IRS, providing crucial relief for clients facing significant tax liabilities. An Offer in Compromise allows taxpayers to settle their tax debts for less than the full amount owed when they can demonstrate that paying the full amount would cause financial hardship. This program represents a vital opportunity for eligible individuals and businesses to achieve a fresh start by resolving outstanding tax obligations. Additionally, our firm skillfully arranges payment plans, also known as installment agreements, with the IRS. These plans enable taxpayers to pay their debts over time in a manageable way, helping to avoid more severe collection actions. Our attorneys are adept at analyzing clients' financial situations, advising on the best course of action, and advocating on their behalf to secure favorable terms that align with their ability to pay.