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TAX CONTROVERSY

TAX CONTROVERSY

Tax disputes arise with or without careful planning. Filed tax returns can be audited and oftentimes disagreements ensue. Business operations with employees and sales taxable transactions may also create tax issues resulting in potential personal liability of the owners. Economic strains or reversals may lead to the underpayment of taxes, penalties and ultimately pressures from the collection agents of the taxing authorities.

Our Tax Controversy Practice Group assists individuals and businesses in resolving differences with federal and state tax authorities in audit, administrative appeals, litigation, and collection activity. While an understanding of the tax law is essential when the IRS or a state or local tax authority is conducting an audit or pursuing collection, an understanding of the process and a rapport with the government agents is also invaluable. Our clients have the benefit of our extensive experience in dealing with the various taxing authorities at all levels.

    • Our Tax Controversy attorneys have helped sort out a range of issues associated with federal and state income tax obligations including:

      • Filing Issues
      • Removal of penalties
      • Audits
      • Appeals and litigation after audit
      • Collection issues (liens, levies, payment plans, settlement offers)

       

    • Our Tax Controversy attorneys have helped sort out a range of issues associated with New York State sales tax issues, including:

      • Audits/Appeals
      • Removal of penalties
      • Personal liability of owners and officers
      • Collection issues (liens, levies, payment plans)

       

    • Our Tax Controversy attorneys have helped sort out a range of issues associated with federal and state payroll tax obligations including:

      • Filing issues
      • Audits/Appeals
      • Removal of penalties
      • Missed payments or late payments
      • Personal liability of owners and officers
      • Collection issues (liens, levies, payment plans)

       

    • When federal taxes are due, the IRS has a range of tools that it can employ to pursue collection. Our Tax Controversy attorneys are very adept in negotiating with the IRS to ensure that disruptive collection action is not occurring while arrangements are made to address the outstanding obligations.

    • When state taxes are due, NYS has a range of tools that it can employ to pursue collection. Our Tax Controversy attorneys are very adept in negotiating with the NYS to ensure that disruptive collection action is not occurring while arrangements are made to address the outstanding obligations.

    • Some tax obligations can be discharged in bankruptcy, others cannot. If a bankruptcy is being considered, our Tax Controversy attorneys can help evaluate which tax debts can be resolved by a bankruptcy filing.

    • Both the IRS and NYS will consider accepting less than full payment of taxes owed, sometimes substantially less. Our Tax Controversy attorneys have extensive experience in negotiating the most favorable terms for such settlements.

    • The failure to file tax returns can have serious ramifications. Fortunately both the IRS and NYS offer programs that can significantly limit the impact when one or more returns are unfiled. Our Tax Controversy attorneys can help evaluate how best to address unfiled returns with the goal of minimizing the consequences of that situation.

    • There are occasions when one spouse is not, or should not be, held responsible for the other spouse’s (or former spouse’s) tax obligation. Our Tax Controversy attorneys can help evaluate and obtain relief when those occasions arise.

    • When taxes go unpaid both the IRS and NYS have powerful tools to protect their claims and collect taxes from third parties such as banks and employers. Our Tax Controversy attorneys can help taxpayers deal with, minimize and oftentimes avoid these severe and aggressive collection activities.

    • US taxpayers are required not only to report income from assets held worldwide, but also there is an obligation to disclose the existence and location of certain financial assets held in another country. The failure to follow these basic disclosure requirements can lead to very serious penalties. Our Tax Controversy attorneys can advise how best to address these issues.

    • If tax returns are filed late and/or payment is delayed, both the IRS and NYS routinely assess significant penalties. Sometimes circumstances beyond a person’s control are the reason for these problems. Our Tax Controversy attorneys can evaluate when penalties are not appropriate and help to have them removed.

    • Both the IRS and New York State continue to audit tax returns of all types. Oftentimes there are complex factual and legal issues which require greater expertise than tax preparers or accountants are able to provide. Our Tax Controversy attorneys have considerable experience in handling such matters, both during the audit process and through the administrative and judicial appeal process thereafter.

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