IRS Tax Audits & Litigation
New York IRS Tax Attorneys with Decades of Experience Handling Audits and Litigation
Any time you face scrutiny from the Internal Revenue Service (IRS), you need to ensure that you are making informed decisions based on the advice of counsel. Not only can audits be invasive, complex and time-consuming, but they can also be very costly. Individual and corporate taxpayers frequently find themselves needing to appeal audit determinations resulting in substantial liability—either at the IRS’s Independent Office of Appeals or in federal court.
A New York IRS tax attorney at Thorn Law Group can help if you are facing a tax audit or litigation with the IRS. Our attorneys have decades of experience protecting clients against unwarranted tax liability, interest and penalties. We can advise you and communicate with the IRS on your behalf; and, if necessary, we can litigate against the IRS on your behalf at the U.S. Tax Court, U.S. District Court or U.S. Court of Federal claims.
Matters We Handle
We handle all types of federal tax audits, appeals and litigation for clients in New York and around the world. If you need advice or representation for any of the following, we encourage you to speak with a New York IRS tax attorney at Thorn Law Group as soon as possible:
IRS Tax Audits
The IRS tax audits hundreds of thousands of tax returns every year. While the IRS will audit any returns that present red flags for tax evasion or tax fraud, it has been paying particular attention to businesses and high-income taxpayers in recent years. If you received an audit notice from the IRS, you need to be very careful about how you respond, and you need to ensure that you are prepared to deal with the IRS effectively.
At Thorn Law Group, we assist individual and corporate taxpayers with IRS tax audits including (but not limited to):
- Individual Income Tax Audits
- Corporate, Partnership and LLC Tax Audits
- Payroll Tax and Trust Fund Audits
- Affordable Care Act (ACA) Audits
- IRS Employee Retention Credit (ERC) Audits
- IRS Paycheck Protection Program (PPP) Audits
The IRS conducts three types of audits. While these audits vary in terms of their invasiveness, they all present equal risks. If revenue agents uncover evidence of underreporting, underpayment or any other tax law violation, they can immediately impose liability for back taxes, interest and civil penalties. If revenue agents uncover evidence of a willful violation of the law during an audit, they can also refer the matter to IRS Criminal Investigation (IRS CI) for further inquiry.
Correspondence Audits
Correspondence audits are conducted by mail, and they are the most common type of IRS tax audit by far—accounting for approximately five out of every six audits the agency initiates. During correspondence audits, taxpayers must submit requested information to the IRS for review, while also being careful to ensure that they do not inadvertently disclose unnecessary information or accept unwarranted determinations of liability.
Office Audits
An office audit involves an in-person meeting with revenue agents at the IRS’s offices in New York. Tax payers summoned to the IRS’s offices must ensure that they are thoroughly prepared. This means being prepared not only to answer revenue agents’ questions effectively, but also to avoid miscues that could expand the scope of the inquiry or lead to financial consequences that could (and should) have been avoided.
Field Audits
Field audits take place at taxpayers’ homes or offices. These are the most invasive type of IRS tax audit, and it is critical that taxpayers have representation throughout the process. If you or your company is facing a field audit in New York, our attorneys can get to work immediately to help ensure that you are fully prepared.
Going to the IRS Independent Office of Appeals
If you need to challenge the outcome of an IRS tax audit, your first step may be to go to theIRS Independent Office of Appeals. This office is “separate and independent from the IRS examination and collection functions that make tax assessments,” and it makes “objective and impartial decisions” outside of litigation.
Even so, going to the IRS Independent Office of Appeals can present a variety of challenges for taxpayers. To successfully appeal audit determinations, taxpayers must be able to clearly demonstrate how revenue agents’ methods or conclusions were flawed. If you are thinking about going to the IRS Independent Office of Appeals, our attorneys can advise and represent you every step of the way.
Going to the U.S. Tax Court
In some cases, it will be more advantageous for taxpayers to go to the U.S. Tax Court than the IRS Independent Office of Appeals. Taxpayers can also challenge administrative decisions in the U.S. Tax Court if their initial efforts to challenge their audit outcomes are unsuccessful. At Thorn Law Group, we have extensive experience representing clients in the U.S. Tax Court, and we can use this experience to seek a just outcome on your behalf by all means available.
Tax Litigation in U.S. District Court or the U.S. Court of Federal Claims
We also have significant experience handling tax litigation in U.S. District Courts and the U.S. Court of Federal Claims. If one of these courts is the correct venue for your tax dispute with the IRS, our attorneys can litigate your dispute with an eye toward settlement while also fully preparing for trial. After the U.S. District Court or the U.S. Court of Federal Claims, the next step is to go to the appropriate U.S. Circuit Court of Appeals, and we handle appellate litigation on behalf of our clients when necessary as well.
Speak with a New York IRS Tax Attorney at Thorn Law Group
If you would like to know more about our IRS Tax Audits & Litigation practice, we invite you to get in touch. We are more than happy to discuss anything you would like to know and help you make informed decisions about your next steps. To speak with an experienced New York IRS tax attorney at Thorn Law Group in confidence, please call (914) 534-6004 or contact us confidentially online today.
