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Pennsylvania

Pittsburgh

We handle IRS disputes across Western Pennsylvania, from gas royalty notices to audits of executive pay at hospitals and universities.

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Some of the IRS problems we see in Pittsburgh come from the region's economy. If you help run a tax-exempt hospital system or university, the IRS can question your pay under the excess benefit rules. If your family leases land for natural gas, royalties left off your return can bring a CP2000 notice.

We also work with clients across the Ohio and West Virginia lines.

Whiteford Tax Defense represents individuals, business owners, and closely held companies across Pennsylvania in federal tax disputes. We handle them from the first notice through appeals and into court.

Whether you have an IRS examination letter, an appeal, or another tax matter, talk with us. We will tell you what the deadline is and what your options are.

Get directions 11 Stanwix Street, Suite 1400 By appointment only. to the Pittsburgh office (opens Google Maps in a new tab)

Common matters we see here

Local regulators & venues

U.S. Tax Court

Pennsylvania has two designated places of trial: Pittsburgh and Philadelphia. The court holds its Pittsburgh sessions in the Moorhead Federal Building at 1000 Liberty Avenue (Room 1108), a short walk from our office. A Tax Court case over a deficiency, meaning extra tax the IRS says you owe, can be tried here.

Taxpayer Advocate Service, Pittsburgh office

The Taxpayer Advocate's Pittsburgh office shares the Moorhead Federal Building with the Tax Court, at 1000 Liberty Avenue. It is one of two in Pennsylvania; the other is in Philadelphia. This independent part of the IRS offers free help with problems that are causing financial hardship or have stalled in the usual channels. It can get a stuck case moving. But it cannot change a legally correct assessment or extend a Tax Court filing deadline.

U.S. District Court, Western District of Pennsylvania (Pittsburgh Division)

The Pittsburgh Division sits in the Joseph F. Weis, Jr. U.S. Courthouse on Grant Street. It covers Allegheny, Armstrong, Beaver, Butler, Clarion, Fayette, Greene, Indiana, Jefferson, Lawrence, Mercer, Washington, and Westmoreland counties. That courthouse hears refund suits and federal criminal tax cases from those counties.

U.S. Attorney's Office, Western District of Pennsylvania

This is the federal prosecutor for the district. It works from 700 Grant Street, in the same courthouse as the Pittsburgh Division, and from branch offices in Erie and Johnstown. Its tax cases here have included evasion, willful failure to file, and employment tax fraud.

U.S. Court of Appeals for the Third Circuit

This court sits in Philadelphia and hears appeals from the Western District. It also hears Tax Court appeals from Pittsburgh households and from companies whose principal place of business is here.

Clients across state lines

Near the Ohio and West Virginia lines, where you live can decide which appeals court hears your Tax Court case. An individual's appeal goes to the circuit where they legally reside. A corporation's goes to the circuit of its principal place of business. So a Pittsburgh household would appeal to the Third Circuit, one in Wheeling to the Fourth, and one in Youngstown to the Sixth. That is true even if all three cases are tried in the same Liberty Avenue courtroom.

The circuit's case law matters long before any appeal. Under the Golsen rule, the Tax Court follows the case law of whichever circuit would hear the appeal. The Internal Revenue Manual tells IRS Appeals officers to consult Counsel, the IRS's lawyers, when that rule applies. So circuit law can shape a settlement as well as a trial.

IRS practice is federal, so we also take on examinations handled by IRS staff elsewhere in the country. And we help clients here who must file in Maryland, Virginia, New York, or any other state with a Whiteford office.

Tax Court or district court, both downtown

Most IRS disputes are handled by mail, by phone, or through the Independent Office of Appeals, so your lawyer does not have to be in Pittsburgh. Location starts to matter when a dispute moves past Appeals.

In a deficiency case, you can petition the U.S. Tax Court without paying the tax first. A refund suit in the district court comes after you pay the tax in full and file a refund claim.

Some taxes are divisible, such as the trust fund recovery penalty and employment taxes. For those, you may sue after paying only the share for one employee for one quarter. That smaller payment is what makes a refund suit practical in responsible person cases.

Pittsburgh makes the choice between the two courts unusually convenient: both sit downtown, a few blocks apart, so neither one means travel. Which court to use still deserves careful thought, usually well before Appeals closes the file.

What we handle

IRS Audits

What an IRS audit involves, why the IRS opens one, and how an attorney protects your position from the first letter.

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IRS Collections

What the IRS can do to collect a tax debt, the rights that apply at each step, and the ways to stop enforcement.

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White Collar Tax Defense

When the IRS treats a tax problem as a crime, what conduct is charged, and how a defense attorney answers it.

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A note on admissions Federal tax matters are handled nationwide, including IRS examinations, appeals, collection, and Tax Court litigation. Pennsylvania state and local tax matters are handled together with Whiteford attorneys admitted in Pennsylvania, or with co-counsel where a matter requires it.

Why taxpayers choose Whiteford

  • Whiteford has been a full-service firm since 1933, and its employment, corporate, bankruptcy, and white collar lawyers are our colleagues.
  • Free initial consultations, where you can find out if our attorneys can help with your matter.
  • If your issue is better addressed elsewhere, or does not call for a lawyer, we will say so.

Frequently Asked Questions

I help run a Pittsburgh hospital system or university. Could the IRS tax me personally over my pay?
It can, if the institution is a tax-exempt charity and the IRS finds your pay worth more than your services. The excess benefit rules put that tax on the insider who received the benefit, not the institution. An insider is anyone in a position to exercise substantial influence over the institution's affairs in the prior five years. A much larger second tax follows if the excess is not corrected. Correction usually means repaying it with interest. Directors or managers who knowingly approved the pay can owe their own tax.
What can a hospital or university board do before an audit to protect executive pay?
The key protection under the excess benefit rules has to be in place before any audit begins. Pay is presumed reasonable when board members with no conflict of interest approve it in advance. They must also rely on appropriate comparability data and document their decision at the time. The IRS can overcome that presumption only with enough contrary evidence to rebut the data the board relied on. In an examination, that record is where the defense begins.
Our family leased land in Washington County for natural gas, and the IRS says the royalties never made it onto our return. How do we answer?
Usually with a written reply to a CP2000 notice. The IRS sends one when information from a third party does not match your return. Here, the company paying the royalties reported them on Form 1099-MISC. The CP2000 is a proposal, not a bill, and your answer is due by the date it gives. Your reply can also raise what the IRS left out. Royalties from a lease like this belong on Schedule E. If you hold an economic interest in the minerals, you may be able to deduct depletion.
We were also paid a bonus for signing the gas lease. Is that taxed too?
Yes. A bonus paid for signing the lease is income, but percentage depletion does not apply to it. Federal income tax is generally not withheld from bonus or royalty payments. So you may need to make estimated tax payments to keep next year's royalties from arriving as a balance due.
How often does the Tax Court come to Pittsburgh?
Less often than in Philadelphia. The court publishes its travel schedule in advance, one term at a time. Recent terms have included a Pittsburgh session only occasionally, but each has included Philadelphia. Your place-of-trial request may name either city. Since September 8, 2026, regular and small tax cases can both be heard at every place of trial. So choose with care. Once a case is pending, you can ask for a different city with the court's Motion to Change Place of Trial. Each term also has remote sessions.
What does the first call involve?
Have the IRS letter or notice with you when we talk. We will work out what it is and what deadline it sets, then explain the realistic paths forward. You do not need the whole file for that call. The notice and the tax years listed on it are enough. If the matter carries criminal exposure, or only a few weeks remain before the deadline, we will tell you on the call, not later.
My IRS notice sets a deadline a few weeks from now. Is there still time to get help?
In most cases, yes. A statutory notice of deficiency gives you 90 days to file a Tax Court petition. The statute sets that period, and the IRS cannot extend it. The 30-day letter that proposes examination changes is different. Its deadline is administrative, and the IRS routinely extends it, often informally or by phone. Contact us as early in the window as you can, because your options narrow sharply once a deadline passes.

Meet Michael

Michael March
Michael March
Partner, Co-Chair Tax Section
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