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Tax Controversies

Guidance Through Complex IRS Negotiations

Despite pressure and demands from tax regulatory bodies, taxpayers are entitled to many protections while under investigation in a tax controversy or while being pursued for tax collection. Leveraging these protections and navigating the complex process efficiently are paramount to reducing the potential for an adverse determination.

Saul Ewing Arnstein & Lehr’s Tax Controversies Practice has represented hundreds of individuals—both American citizens and those holding foreign passports—and businesses around the world to resolve matters with the Internal Revenue Service (IRS) and various state agencies that involve tens of thousands to many millions of dollars. Our team of skillful negotiators has a tremendous amount of experience with the administrative arm of the IRS, and is also experienced in litigating tax matters in the courts when required or otherwise necessary. Our clients should only pay the proper amount of tax.

Our team consisting of former IRS attorneys and other former IRS enforcement officers regularly handles:

  • Audits
  • Seizures of wages and bank accounts
  • Disclosures of offshore accounts
  • State tax problems
  • Federal tax liens
  • Innocent spouse issues
  • Criminal investigations
  • International tax compliance
  • Tax appeals
  • Negotiations to decrease IRS penalties
  • Tax litigation in the United States Tax Court, district courts and Court of Federal Claims
  • Taxpayer rights matters
  • IRS collection issues

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Robert E. McKenzie
Adam Fayne