So, we keep using this word controversy.
Tax controversy is a cool way of referring to the practice of law involving disputes between tax collection entities such as the IRS or state tax agencies, and taxpayers. So why can’t you just say litigation like all the other attorneys that go into a court room? Because with tax there’s way more involved, as always.
When the IRS claims you owe additional amounts (whether from an audit, adjustment, or other method of assessment) tax controversy is the process by which you the taxpayer assert your rights to disagree with their adjustment. The IRS usually just sends you a notice stating you owe them money. That notice represents the IRS’s opinion on your tax matter. Just because the IRS says you owe money doesn’t mean you actually owe that amount. Frequently the IRS makes mistakes on key facts of your situation or has a mistaken interpretation of the law. If you just ignore the letter and do nothing you’re agreeing with what they say. If you don’t agree with what they say you have to respond and assert your rights.
Each tax matter will be different depending on the facts and circumstances of the situation. However, generally there is an opportunity to appeal any adjustment and also the opportunity to file in Tax Court, District Court, or the Court of Federal Claims. Tax controversy can cover many different taxes: income, excise, employment, or any other tax.
We can represent you in these types of matters. You will you no longer have to talk to the IRS and we can often clarify the situation and provide a more accurate interpretation of the law as it applies to your matter.