Find Lawyers in Dallas, Texas for Litigation and Controversy - Tax
John Brusniak, Jr. has been a nationally recognized property tax attorney for 30 years. Before starting his own firm, John was a partner in two of Texas’ largest law firms. As a result of his ground-breaking appellate and other successes, Texas property tax law bears his personal mark. He is a frequently sought speaker and publisher of property tax articles, as well as his own reference book, Brusniak’s Texas Property Tax Digest . John is also the author of Texas Property Tax Code Practice In...
Mary McNulty represents corporations and partnerships in IRS audits, appeals, and tax litigation and provides tax planning for partnerships, limited liability companies, and S corporations. She specializes in Federal tax procedural issues, including statutes of limitations, interest, penalties, privilege, and TEFRA partnerships, and in partnership tax issues relating to private equity, oil and gas, wind energy, real estate, and exempt organizations.
Litigation and Controversy - Tax Definition
Tax litigation and controversy broadly describes the practice of resolving tax disputes with federal, state, local, and foreign tax authorities. A tax controversy may involve a business (whether for-profit or not-for-profit), trust, estate, or individual, and can result from any form of taxation, including income tax, estate and gift tax, state sales and use tax, or local property tax. In general, tax disputes are separated into civil and criminal matters.
Attorneys specializing in tax controversies may assist a taxpayer in a civil matter by providing expertise regarding substantive tax laws, dealing with revenue agents, formulating audit strategies, and pursuing administrative or judicial appeals. Although litigation is usually the option of last resort for most taxpayers, an experienced attorney can provide skillful representation in court proceedings. A tax attorney can play a leading role in resolving a tax controversy or simply serve as an advisor to the taxpayer or his or her accountant. In addition, an attorney may assist the taxpayer in planning transactions to avoid future disputes.
Civil tax matters usually begin with audit, assessment, and collection activities by a taxing authority. Alternatively, a controversy may be initiated by a taxpayer claiming a refund. At the federal level, resolving a civil tax controversy may require discussions with the IRS, a written appeal to and discussions with the Appeals Office, or, potentially, litigation in the United States Tax Court, District Courts, or Court of Federal Claims. After litigation of a case in a lower court, the taxpayer may have appeal rights in the federal appellate courts. A similar process is available in resolving civil tax controversies at the state and local levels.
An international tax attorney may assist a taxpayer in resolving issues with taxing authorities in foreign jurisdictions or involving issues arising in international transactions, including advanced ruling requests to achieve tax certainty and penalty protection, competent authority requests to resolve treaty issues, advanced pricing agreements to resolve transfer pricing issues, and using voluntary disclosure programs to prevent or reduce tax penalties.
Criminal tax matters involve taxpayers alleged to have evaded taxes or otherwise willfully violated the tax laws. Tax litigators can assist such taxpayers by representing them during criminal investigations by the IRS, the Justice Department, or state taxing authorities, and in criminal trials, sentencing proceedings, and appeals.
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