Tax Defense

A portion of my practice has long been devoted to representation of taxpayers in civil controversies with the IRS and California taxing authorities. During the past 40 years I have represented taxpayers in more than 1,000 cases, including more than 500 cases filed in the United States Tax Court. Here are the types of cases I have taken:


Internal Revenue Service Controversies

    * IRS examinations

    * IRS appeals - protests and conferences

    * IRS collection due process (CDP) hearings

    * IRS Office of Professional Responsibility (OPR) proceedings


United States Tax Court Litigation

    * U.S. Tax Court deficiency litigation

    * U.S. Tax Court declaratory relief litigation


United States District Court Litigation

    * Summons enforcement defense

    * Freedom of Information Act disputes

    * Refund claims

    * Unlawful IRS disclosure

    * Appeals to the U.S. Courts of Appeals


California Tax Audits

    * Franchise Tax Board audits

    * Franchise Tax Board protests

    * Sales tax audits

    * State Board of Equalization protests and hearings

    * Superior Court refund claims

    * Appeals to the California Court of Appeals


Although I cannot as a matter of professional responsibility guarantee results, I can report that in all but a small handful of cases I have been successful in obtaining the reduction or elimination of the deficiency and/or penalties proposed. In nearly every case the result was obtained at a cost to the taxpayer in legal fees that was significantly less than the savings obtained.


My strategy is to fully develop the applicable facts and law, and to deal with the IRS of Government counsel in a forthright manner with a view toward settlement of the case based on its merits. I have been successful in negotiating settlements in 99% of my cases. Where necessary, however, I have been willing and able to try cases in court. To see a listing of published cases in which I have appeared, see Published Cases.