Tax Controversy and Litigation

Changing tax laws, coupled with rigorous enforcement actions by the IRS, have resulted in an increase in the number of IRS examinations and prosecutions in the U.S. in recent years. Ober|Kaler’s Tax Group has a deep understanding of the workings of the IRS – both from the first hand experience of our attorneys whose career paths began inside the agency, as well as from our years of litigating cases in IRS tax and appellate courts and in federal district courts throughout the country.

Our clients know that when an issue arises, they can count on our attorneys to be engaged and accessible when they need them the most. We understand that audits and tax controversies can be intimidating. We also know how important it is to quickly assess the situation and plan the appropriate course of action in order to minimize business disruption and long-term negative financial impact. We tailor our approach to each client’s individual situation and develop a pragmatic legal strategy that is aligned with the issues surrounding each case.

We have extensive experience on IRS collection-related matters, including Offer-in-Compromise cases; negotiating installment agreements, levy releases, tax lien releases and tax lien withdrawals; tax lien subordination and related priority matters. Our representation includes counseling clients on various voluntary compliance and amnesty and post amnesty program issues, including FBAR cases.

Ober|Kaler’s deep experience in federal, state and local tax controversy matters includes representations of all types of business entities, entrepreneurs and individuals in matters related to: 

• IRS examination and appellate matters
• IRS practice and procedure
• IRS tax court litigation and refund cases
• IRS collection matters, Collection Due Process and CAP hearings
• Federal excise tax audits
• Civil and criminal fraud
• Penalty and interest abatements
• Levy/Wage garnishment releases and withdrawals
• Foreclosure and seizure actions
• Offer-in-Compromise negotiations
• Trust Fund Recovery Penalties (TFRP)
• Private Letter Rulings
• IRS Technical Advice Memoranda (TAM) 
• Fast-track mediation 
• Federal and state amnesty programs
• FBAR representations