Federal Tax Controversy Services 

Our practice can help you prepare for, anticipate, understand and strategically respond to the IRS at all stages of the process.

Beginning with the planning phase, our professionals are available to assist you in documenting and substantiating your transactions and positions, so that your company is ready, should the issue be challenged. We can also work with you even before a dispute arises, to obtain certainty through advance rulings or Pre Filing Agreements (PFAs). This can provide a significant savings of both time and expense, and help clarify your position before it is reported on your federal income tax return.
Our services cover, but are not limited to:

    Transaction Documentation Assistance

  • We can work with you during the planning phases of your transactions to ensure correct documentation.

    General Examination Tax Consulting Assistance Including Pre-Filing / Pre-Examination Assistance

  • We assist during the examination, and assist with pre-filing procedures such as advance rulings, PFAs and Voluntary Disclosure Agreements (VDAs).

    Exam Guidance and Traditional Appeals Assistance

  • During the Examination phase, we can assist with data accumulation and preparation of responses to Information Document Requests (IDRs) and other requests for information. We also provide strategic consulting advice, prepare protests to Appeals, and represent clients during the Appeals process.

    Alternative Dispute Resolution (ADR)

  • We represent you in all ADR processes including Fast Track Mediation, post Appeals Mediation and post Appeals Arbitration.

    Interest Computation and IRS Transcript Review

  • The Complex Interest practice analyzes and identifies errors on IRS transcripts, which may reduce interest liabilities or generate refunds on your behalf. In addition, the group performs interest computations and can work with IRS interest professionals to help ensure correct and accurate computations.

    9100 Relief (Missed Elections)

  • We can determine your qualification to obtain automatic relief under the statute (9100 Relief) for failure to make certain tax elections by the due date and assist in obtaining a private letter ruling if necessary.

    Assistance With and Filing of Form 1139 (Corporate Application for Tentative Relief)

  • We can assist you with filing for a quick refund of taxes on the carryback of a net operating loss, net capital loss or unused general business credit or an overpayment of tax due to a right of adjustment claim under section 1341 (b)(1).

Contact:

Sharon Katz-Pearlman, National Principal in Charge