IRS Audits and Litigation
Massachusetts Tax Audit Lawyer- IRS Federal Tax Litigation
The legal team at Thorn Law Group has extensive experience handling IRS audits and federal tax litigation for clients in the Boston area and across the United States. We understand the tremendous pressure our clients face when they are the subject of an IRS tax audit. As former attorneys for the Internal Revenue Service, we have a keen understanding of IRS operations and procedures and know how revenue agents handle these types of IRS investigations. Each Massachusetts tax audit lawyer at our firm focuses on resolving our clients’ tax controversies quickly and efficiently through the IRS audits and appeals process. When our clients are not able to achieve a positive outcome through these administrative avenues, we are prepared to litigate our clients’ tax disputes at all levels of the federal court system.
The attorneys at Thorn Law Group are seasoned federal tax litigators with decades of experience practicing before the IRS, the federal courts, and various administrative bodies and professional tribunals. Litigating a tax case in federal court can be a challenging process requiring the skills and knowledge of an experienced Massachusetts tax audit lawyer. The legal professionals at our firm are extremely familiar with the various forums available to litigate IRS tax disputes. In addition to working as trial attorneys with the IRS before entering private practice, several of our lawyers have also served as law clerks with the United States Tax Court. This unique background positions our attorneys to strategically review cases and assist our clients in selecting the best forum available to litigate their federal tax cases.
IRS Litigation - Selecting a Federal Forum
When taxpayers are unable to secure favorable outcomes through the IRS audits and appeals process, they have the right to litigate their IRS tax disputes in the federal court system. While most IRS federal tax cases are brought before the U.S. Tax Court, these cases can also be litigated in the United States District Court and the United States Court of Federal Claims. The United States Tax Court specializes in adjudicating cases involving federal income tax disputes.
The Tax Court is unique in that the taxpayer is not required to prepay the tax amount in dispute before litigating the case. Rather, payment is not required until the Tax Court reaches a final decision and any and all appeals to the U.S. Circuit Court of Appeals are concluded.
Taxpayers may also elect to litigate their case in a U.S. District Court. This venue is unique because it is the only forum that allows for the dispute to be tried before a jury. Unlike the U.S. Tax Court, U.S. District Courts require taxpayers to make payment of the proposed deficiency before they are permitted to litigate their case.
Additionally, taxpayers are required to exhaust all IRS administrative remedies before they will be permitted to litigate their dispute in a U.S. District Court. Beyond the U.S. District Court and the U.S. Tax Court, taxpayers may also choose to bring a tax refund suit against the IRS in the United States Court of Federal Claims. Similar to the U.S. Tax Court, cases in the U.S. Court of Federal Claims are not tried before a jury; rather, they are heard by a single judge. Taxpayers must also prepay the tax amount due in order to have their case heard by the U.S. Court of Federal Claims.
If you have questions about the IRS audit and litigation processes or would like to discuss your tax situation with an experienced Massachusetts tax audit lawyer, contact Kevin E. Thorn, Managing Partner of Thorn Law Group, at email@example.com or (617) 692-2989.