Tax Controversy

Tax Controversy

Whether handling an entire tax controversy or a discrete element of a specific tax issue that is under audit by a federal or state tax authority, GTC has the experience and expertise to achieve optimal results for clients while using all available administrative procedures and in the most efficient manner possible. Please contact us to discuss the services that we can provide to you in connection with a tax return audit or other tax controversy matter for which your organization needs legal representation.

During the tax audit process, GTC can assist clients in each of the following matters and in a very cost-effective manner in comparison to what it would likely cost a client in order to obtain similar services from most large law firms:
  • Negotiating the scope of a tax audit
  • Formulating IDR responses for documents requested during an audit
  • Responding to or contesting summonses
  • Drafting position papers
  • Obtaining pre-filing agreements, private letter rulings, and technical advice memoranda.
A large law firm normally has a highly specialized tax controversy practice whereby it possesses a special expertise and also charges high hourly rates, which may not be justified for a client who is experiencing a routine non-complex tax audit for which the amount in controversy does not warrant the hiring of a large law firm. GTC can provide effective representation to clients who are involved with these types of tax disputes.

GTC is also intimately familiar with the specialized experience that each large law firm possesses with respect to various types of tax controversies and can effectively advise clients on the best law firms to consider engaging should it become necessary during the course of a matter on which a client has engaged GTC to handle a given tax controversy.

GTC also has experience during the administrative appeals process in resolving disputes with the Internal Revenue Service using the Fast Track Settlement program, traditional appeals negotiations, and we can assist clients in resolving disputes with tax authorities through alternative dispute resolution proceedings such as arbitrations and mediations if we are unable to negotiate a satisfactory settlement during the traditional negotiations that take place during the IRS appeals process.