U.S. Tax Court Litigation

Taxpayers have the right to challenge the findings of a tax audit through U.S. Tax Court Litigation.

The IRS will issue a Notice of Deficiency if the results of the audit are not challenged within 30 days. A taxpayer must then file a petition with the U.S. Tax Court within 90 days of the Notice of Deficiency. Failure to do so means the determination will become final and the IRS may collect the additional tax, penalties, and interest.

A tax audit is a comprehensive investigation into your tax returns, finances, and personal data conducted by the IRS to make sure that your returns are accurate and complete. The IRS starts an audit or examination by mailing an exam notice to the taxpayer. The exam notice provides taxpayers with crucial information related to the audit, including the subject, the scope, the severity, and the type of auditor.

The notice will request the taxpayer to call the IRS auditor within ten days. A savvy taxpayer may elect to have a representative contact the IRS on their behalf. While this call is to schedule the first audit meeting, auditors often try to elicit information in this call.

During an audit, the IRS auditor will request substantial documentation, including bank statements and financially sensitive information, and even possibly interview you for testimony. This information will be used to justify the auditor’s conclusion.

When challenging audit results in U.S. Tax Court Litigation, a Kugelman Law attorney will draft the petition identifying IRS errors as well as raise affirmative defenses.

We will correspond on your behalf with the assigned IRS attorney and conduct discovery. Our attorneys will prepare you for trial, present relevant evidence, and draft all briefs demonstrating the merits of your case to the Court.

Our team of professional U.S. Tax Court attorneys in California can advise and advocate for you in any U.S. Tax Court proceeding. We are well versed in applicable standards, U.S. Tax Court Rules, and burdens of proof. Our goal is to resolve the matter without trial, if possible. Ultimately, we strive to leverage the proceeding in the most advantageous manner for our clients.

Kugelman Law lawyers Alex Kugelman have worked as a U.S. Tax Court clerk and IRS Chief Counsel attorney, respectively, so he is uniquely skilled at representing taxpayers before a U.S. Tax Court Judge.

Contact the Kugelman Law attorneys who have represented clients in California and throughout the country in U.S. Tax Court Litigation.