IRS Audits & Examinations
Representation during IRS audits and examinations, including responding to information and document requests, developing factual and legal positions, communicating with the IRS, and addressing proposed adjustments.
FEDERAL TAX CONTROVERSY
Strategic representation for individuals and businesses facing IRS audits and examinations, administrative appeals, collection matters, federal tax liens and levies, and disputes before the U.S. Tax Court.
Basis Law PLLC helps clients understand what the IRS is asking, where the matter stands procedurally, what deadlines may apply, and what options are available. From responding to an examination through administrative appeals, collection proceedings, and Tax Court litigation, the strategy begins with the facts, the law, and the client’s objectives. Federal tax controversy representation may be available nationwide.
UNDERSTANDING THE PROBLEM
Federal tax controversy involves disputes between taxpayers and the Internal Revenue Service, from the first stages of an examination or collection matter through administrative appeals and, when necessary, litigation in the U.S. Tax Court.
A tax controversy can begin with an IRS notice, audit or examination, proposed adjustment, unpaid tax liability, federal tax lien, IRS levy, or another disagreement concerning a taxpayer’s federal tax obligations. Some matters can be addressed administratively, while others may involve IRS Appeals, collection proceedings, or Tax Court litigation.
Effective representation begins with understanding what the IRS is asking or asserting, identifying the governing law and relevant facts, determining where the matter stands procedurally, and preserving important deadlines. From there, Basis Law evaluates the available options and develops a strategy grounded in the law, the evidence, and the client’s objectives.
How Basis Law PLLC Can Help
Federal tax disputes can arise at different stages of the IRS process. Basis Law represents individuals and businesses in matters involving IRS examinations, administrative appeals, collection actions, federal tax liens and levies, and U.S. Tax Court proceedings.
Representation during IRS audits and examinations, including responding to information and document requests, developing factual and legal positions, communicating with the IRS, and addressing proposed adjustments.
Representation in administrative appeals of disputed IRS determinations, including developing the taxpayer’s position, preparing protests when appropriate, and advocating before the IRS Independent Office of Appeals.
Representation in IRS collection matters, including Collection Due Process (CDP) hearings, Notices of Federal Tax Lien, levies, penalty mitigation, installment agreements, and other available collection alternatives.
Assistance when a federal tax lien affects the sale, refinance, or transfer of real property, including requests for lien discharge, release, or subordination when appropriate.
Assistance evaluating spousal tax issues, including innocent spouse relief under IRC § 6015 and injured spouse allocation when a joint refund is applied to certain debts attributable to the other spouse
Representation in federal tax disputes before the U.S. Tax Court, including evaluating disputed issues, developing legal and factual positions, and navigating the litigation process.
EARLY STRATEGY MATTERS
An IRS notice or request should not be treated as just another piece of paperwork. What the IRS is asking, why it is asking, what the available records establish, and how a response may affect later stages of the matter can all shape the strategy. Early legal involvement can help identify the issues, preserve procedural rights, and develop a well-supported position before the dispute progresses.
Already received an IRS notice, examination request, collection notice, or other correspondence? Bring it to your consultation along with any response deadline and related documents.
Discuss Your Tax MatterA Thoughtful Process
Review the IRS correspondence, identify the issue, determine where the matter stands procedurally, and identify any deadlines requiring attention.
Identify the governing legal and factual issues, what the available evidence establishes, and what additional information may be needed.
Evaluate available response, dispute, or resolution options based on the facts, applicable law, procedural posture, deadlines, and the client’s objectives.
When representation is undertaken, move forward with a defined strategy while reassessing the available options as the matter develops.
TAX CONTROVERSY FAQs
These answers address common questions about IRS notices, audits, collections, appeals, and other federal tax disputes. The appropriate response depends on the facts, procedural posture, and applicable deadlines.
Start by identifying the notice or letter number, the tax year involved, what the IRS is asking or asserting, and any deadline for responding. Do not assume that every IRS notice requires the same response. Some notices provide administrative appeal or other procedural rights that may be affected by a deadline. If you are considering legal representation, preserve the complete notice and any related IRS correspondence.
Depending on the procedural stage of the matter, a taxpayer who disagrees with proposed IRS adjustments may have opportunities to provide additional support, request administrative review, pursue an appeal through the IRS Independent Office of Appeals, or challenge certain determinations in the U.S. Tax Court. The available path and applicable deadlines depend on the correspondence issued and where the matter stands.
The available options depend on the type of notice issued and the stage of the collection process. Certain lien and levy notices may provide Collection Due Process (CDP) rights, which can allow a taxpayer to request a hearing with the IRS Independent Office of Appeals. Depending on the circumstances, collection alternatives or challenges to particular collection actions may also be available. Because some collection rights are deadline-sensitive, the specific notice should be reviewed promptly.
A federal tax lien does not necessarily make a sale or refinance impossible. Depending on the circumstances, the lien may be satisfied from closing proceeds, or a taxpayer may seek a discharge of specific property from the federal tax lien or request subordination of the IRS’s lien interest. The appropriate procedure depends on the property, equity, transaction, tax liability, and other facts.
Innocent spouse and injured spouse relief address two different tax problems. Innocent spouse relief may be relevant when spouses filed a joint tax return that resulted in a joint tax liability and one spouse seeks relief from responsibility for certain taxes attributable to the other spouse or former spouse. In other words, the issue is generally whether one spouse should remain responsible for a joint tax debt.
Injured spouse relief generally involves a refund rather than the underlying joint tax liability. It may become relevant when a joint tax refund is applied to certain debts owed by only one spouse. For example, if one spouse owes past-due child support and the couple’s joint federal tax refund is taken to satisfy that debt, the other spouse may have an injured spouse issue.
These issues can become particularly important before, during, or after a divorce. Prior joint returns, unpaid taxes, pending IRS examinations, refund offsets, and tax liabilities connected primarily to one spouse can all warrant closer review. Divorce itself does not determine whether either type of relief is available; the appropriate remedy depends on the particular tax issue and the surrounding circumstances.
TALK WITH BASIS LAW PLLC
A consultation is an opportunity to discuss your federal tax matter, identify the issues and deadlines that may require attention, and consider possible next steps. It also gives us an opportunity to determine whether Basis Law is the right fit for your matter.