Most tax disputes start with a letter from the IRS. It might be a notice of additional tax owed or a notification of an audit. That letter can cause a sinking feeling in the pit of your stomach, but do not ignore it. If the issue is not resolved early, it can lead to serious consequences. It could even wind up in court. That is why contacting a Richard IRS tax litigation lawyer is the best step to take once that letter comes through the door.
An experienced tax attorney can help you challenge the IRS while also protecting your rights. Litigation may be the final step in a long process, but having their advice early on can take some of the stress out of the situation and set you up for the best possible outcome in your case.
For most individuals and small business owners, the IRS initiates contact through written notices. These include CP2000 letters about unreported income or audit letters requesting documentation for a specific return. In many cases, the taxpayer responds directly or with help from an accountant. Not all disputes end there.
Discrepancies in income, disallowed deductions, and or missing documentation can lead to a proposed tax assessment. If the taxpayer disagrees and the matter cannot be resolved informally, it may trigger a formal appeals process. The decision to litigate often starts here, especially if the IRS insists on enforcing an amount he taxpayer believes is incorrect or unfair. An attorney in Richmond could help before an IRS tax dispute leads to litigation.
The IRS Office of Appeals exists to offer a neutral review outside of the original audit or enforcement unit. Many disputes are resolved at this level, but not all. When appeals officers side with the original IRS findings, the only remaining option may be litigation.
In tax litigation, the case generally proceeds to US Tax Court, which has jurisdiction to hear tax disputes nationwide. Under 26 U.S. Code § 7442, the court handles civil cases, including deficiency notices, penalties, and more. Unlike other federal courts, taxpayers do not have to prepay the tax to bring a case in Tax Court. That makes it more accessible to individuals and small business owners. Taxpayers can also pursue a case in U.S. District Court or the U.S. Court of Federal Claims, but only after paying the disputed tax and suing for a refund.
Regardless of which path the dispute takes, tax litigation is a formal process. It involves written petitions, discovery of records, legal arguments, and potentially a trial. It demands preparation and a deep understanding of tax law.
A Richmond lawyer who focuses on IRS tax litigation understands how these cases unfold. Our experience helps clients avoid costly mistakes while presenting the strongest case possible at every stage of the process.
If the IRS will not back down and an appeal has not worked, litigation may be the next step. It is not an easy process, but with the right representation, it can offer the resolution you could not get anywhere else.
Speak with a Richmond IRS tax litigation lawyer to review your case. Whether you want to settle or fight it out in court, having an experienced legal representative in your corner can make all the difference.