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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.

Client Reviews
Alexander helped me break down my tax situation and used his expertise to figure out the next actionable steps, make sure that all the bases were covered (that I wasn't aware even existed), and confirm that things were done correctly. If you are confused and stuck in a difficult tax situation, Alexander will guide you forward and help you confidently resolve the issue. Henry Wang
If you are having tax trouble, Alexander is the one to help you. He was very professional, personable, and easy to reach. His explanation of the entire process is helpful for easing the stress that is associated with tax trouble. We never felt intimidated or out of the loop while working with him. The process was handled to our liking and we are satisfied with the results. Even the after care has been phenomenal! Tony W.
If anyone out there is in need of stellar legal tax assistance, look no further and contact Alexander Kugelman. He helped me tremendously with my tax situation and is always there to help when needed. If I can give Alexander more stars, I would because 5 stars is not enough! Thank you for everything, Alex!!! Flo Lauzon
Alexander has been a life saver! I got dragged into some serious IRS issues with a complicated foreign assignment component, which included divorce. Alexander has been working with me to resolve directly with the IRS. Alexander is detail oriented, responsive and I trust him to guide me. I will be using Alexander for all tax related matters from now on! He is stuck with me forever. Eve T.
Alexander helped me understand the IRS audit process and prepared my response. There were certain records that I had lost, but he suggested alternatives that the IRS accepted. Even better, he showed up at the audit for me and I never actually had to talk with the IRS. I didn't have to pay any penalties. I'd definitely recommend hiring Alexander to deal with an IRS issue. L.R.