IRS Audits & Litigation
Although most tax disputes are resolved through the IRS audits and appeals procedure, if a favorable outcome cannot be achieved administratively, taxpayers have the right to litigate their cases in the federal court system. The United States Tax Court is the most common forum in which these types of cases are litigated. Cases involving IRS disputes can also be brought before the United States District Court and the United States Court of Federal Claims. Litigating a case in any of these federal courts is a challenging process and a successful result often hinges upon the skills of an experienced federal tax litigator.
Thorn Law Group’s team of trial lawyers specialize in IRS federal tax litigation. We have decades of experience successfully representing clients during the IRS tax audit, appeals and litigation processes. Our clients include individual taxpayers, corporations, partnerships, trusts, estates, high net worth individuals and other entities in the United States and abroad. The legal professionals at our firm worked for the IRS and the U.S. Tax Court before entering private practice. This experience gives each tax lawyer at our firm a strategic advantage when guiding clients through complex federal court procedures.
Selecting the Best Forum for IRS Federal Tax Litigation
At Thorn Law Group, a tax attorney will carefully review your case in order to advise you on the best forum to litigate your IRS tax dispute. Each attorney at our firm is intimately familiar with the rules and procedures for litigating in the federal courts. We understand the unique differences among the courts and the intricacies of federal tax laws.
U.S. Tax Court
The majority of IRS federal tax cases are brought before the U.S. Tax Court. The Tax Court is a specialty court that exclusively hears tax law cases. Cases are tried before a single judge with expertise in tax law. In this forum, taxpayers are not required to prepay the proposed tax deficiency before litigating. Payment is not required until the decision of the Tax Court has been entered and becomes final, including any and all appeals of the Tax Court’s decision. Appeals from the U.S. Tax Court are made to the U. S. Circuit Court of Appeals.
U.S. District Court
In order to bring a case before a U.S. District Court, taxpayers must exhaust all IRS administrative remedies and prepay the disputed tax deficiency. The U.S. District Courts are the only venue in which taxpayers may try their case before a jury. Appeal of a decision by a district court must be made to the Circuit Court of Appeals for the Circuit in which the district court lies.
U.S. Court of Federal Claims
The U.S. Court of Federal Claims only hears cases against the U.S. government. Any person, regardless of citizenship, can file a tax refund suit against the United States in the Court of Federal Claims. The Court of Federal Claims does not hear jury trials; rather, cases are tried before a single judge.
Thorn Law Group Litigates All Types of IRS Tax Disputes
The attorneys at Thorn Law Group have successfully represented clients before the U.S. Tax Court and other federal courts in all types of tax disputes, including income tax problems, payroll tax problems, valuation disputes, TEFRA litigation, excise tax problems, tax collection, tax penalties, and estate tax cases. Our legal team handles all aspects of IRS tax audits and litigation, including:
- IRS Civil Tax Audits
- IRS Administrative Appeals
- Offshore Account/Foreign Bank Account Reporting (FBAR)
- Foreign Trust and Estate Reporting
- Foreign Business Reporting
- Tax Penalty Relief
- IRS Liens, Levies & Seizures
- Employment Tax Disputes
- Worker Classification Audits
- Tax Shelter Investigations
- Tax Shelter Promoter Investigations
- Conservation and Façade Easement Disputes
- Historic Tax Credits
- Return Preparer Penalties