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What is Tax Litigation?

Tax litigation, like all litigation, involves conflicts over law or facts that can be intelligently argued either way. It's just that the issues pertain to tax matters and the other disputing party is the state or federal government.

Do you need help with your unresolved federal tax issues?

If you are suffering or about to suffer a significant hardship as a result of the administration of tax laws, contacting the Taxpayer Advocate Service may help. The Taxpayer Advocate Service is an independent organization within the IRS, headed by the National Taxpayer Advocate. The Taxpayer Advocate Service is located at local IRS Tax Assistance Centers. Call toll-free at (877) 777-4778 to find an IRS Tax Assistant Center near you. The Taxpayer Advocate Service can help you:

• File innocent spouse claims if you believe you are not liable for your spouse's share of a joint tax liability;
• Make an installment agreement if you cannot pay your taxes in full;
• Prepare an offer in compromise (OIC) Form 656 to settle an unpaid tax debt;
• Request a release of federal tax liens and levies when appropriate; and
• Resolve IRS account and notice issues.

To authorize another person or organization to receive and inspect your confidential tax return information, and represent you before the IRS, complete the Power of Attorney and Declaration of Representation (Form 2848) and send it to where the instructions indicate. Use Form 8820, Tax Information Authorization, if you want to authorize an individual or organization to receive or inspect your confidential tax return information, but do not want the individual or organization to represent you before the IRS.

Download this guide for more information about the Taxpayer Advocate Service. If you need to speak with an IRS representative and get tax help by phone, call 1-800-829-1040. Please note that the Taxpayer Advocate Service is not a substitute for established IRS procedures or the formal Appeals process. The Taxpayer Advocate Service cannot reverse legal or technical tax determinations. The Taxpayer Advocate Service also is not able to help with state taxation issues.

For matters of this nature and other possible tax law issues, you should immediately consult with a tax litigation attorney. A tax litigation attorney may be able to help you with issues such as:

• State and Federal Administrative and Court Proceedings
• Corporate Tax Matters
• Criminal Tax Litigation
• Federal and State Tax Disputes and Controversies
• Federal Refund Litigation
• Installment Agreement Request - Form 9465
• International Tax Matters
• IRS Appeals - Post Appeal Litigation
• IRS Audits - Post Audit Litigation
• Partnership Tax Matters
• State Department of Revenue Hearings and Litigation
• Statutory 90 Day Notices
• Taxation
• Tax/Bankruptcy Litigation
• Tax Collection
• Tax Crimes
• Tax Court Petitions
• Tax Evasion
• Tax Fraud
• Tobacco License Appeals Hearings and Litigation
• Tax Lien Releases
• Withholding Tax Litigation

Should I hire a Tax Litigation Attorney?

You should never go unrepresented before the Appeals Division of the Internal Revenue Service, the United States Tax Court or any state tax courts. Use the search form at the top of this page to find a qualified tax litigation attorney to assist you with your legal needs now.

Frequently Asked Questions

• What Rights do Taxpayers Have When Dealing With the IRS?
  IMost people consider any dealings with the IRS to be very stressful and frustrating.  Keep in mind that taxpayers have important rights when dealing with the IRS.  In fact, the IRS has … more
• What is the IRS Appeals Office?
  If you disagree with the IRS findings in your case, you can appeal your case to the Appeals Office of the IRS. The local Appeals Office is separate from and independent of the IRS office that … more
• How Does the IRS Determine Which Tax Returns to Audit?
  According to the IRS, tax returns are selected to be audited in one of two ways:  (1) the IRS uses computer programs to identify returns that may have incorrect amounts. These programs may be … more
• What Protections are Taxpayers Entitled to When They Have a Dispute with the IRS?
  When taxpayers have a dispute with the IRS, they are entitled to the following minimum protections from the Appeals Office: Appeal disputes arising under the Internal Revenue Code, regulations and … more
• What is an Installment Agreement?
  If you owe the IRS money, but can't pay it in one lump sum, the IRS might allow you to pay according to an "Installment Agreement."  Installment agreements allow the payment of your … more

Free Legal Forms

• IRS Form 656: Offer in Compromise
  IRS Form 656 is used to make an offer to compromise your liability for payment of less than the full amount owed.
• IRS Form 843: Claim for Refund and Request for Abatement
  IRS Form 843 is submitted to claim a refund (or abatement) of certain overpaid (or over-assessed) taxes, interest, penalties, and additions to tax.
• IRS Form 9423: Collection Appeal Request
  IRS Form 9423 is used to appeal a collection action. Using this form, you may request an appeal of the following actions: notice of federal tax … more
• IRS Form 12203: Request for Appeals Review
  This form can be used to request an Appeals review of a proposed IRS adjustment of $25,000 or less per tax year or period.