Examinations · Appeals · U.S. Tax Court
The IRS has attorneys.
You need one too.
When a tax problem is past the point of phone calls — an audit going badly, a 90-day letter, a trust fund interview, agents at the door — the answer isn’t a tax relief company. It’s counsel. 32 years of it, admitted to the United States Tax Court.
U.S. Tax Court
Admitted to practice
$100M+
Tax debt resolved
32 yrs
Federal tax work
Privileged from the first sentence. What you’ve told your CPA is discoverable. What you tell your attorney is not. Here’s why that matters →
How IRS disputes escalate
Four rungs between you and the courtroom
Every rung has its own rules, its own deadlines, and its own leverage. Most cases should settle on rung two. Knowing how rung four works is why they do.
Examination
The audit. Scope control, document strategy, and never sitting with the agent alone.
Read the guide →
30-Day Letter → Appeals
A written protest moves the case to officers with authority to weigh hazards of litigation and settle.
Read the guide →
90-Day Letter
The Notice of Deficiency. Ninety days to petition Tax Court. The deadline is jurisdictional.
Read the guide →
U.S. Tax Court
Litigate before paying, in front of judges who hear nothing but tax. Trial sessions sit in Tampa.
Read the guide →
Matters handled
Attorney-level IRS work
These are the matters where counsel changes the outcome — privilege, procedure, and the credible ability to litigate.
Litigation & the courts
Filing a Tax Court Petition from Tampa
The U.S. Tax Court lets you challenge the IRS before paying. Filing requires meeting strict deadlines.
Federal Tax Litigation in Tampa
When the IRS won\'t negotiate, the courtroom is where the answer lives.
IRS Appeals Attorney in Tampa
IRS Appeals has broad settlement authority. An attorney gets better results.
IRS Lien Litigation Tampa
When administrative remedies fail, litigation forces lien resolution.
IRS Penalty Litigation Tampa
When penalty abatement is denied, litigation is the next step.
High-stakes defense
Criminal Tax Defense in Tampa
IRS Criminal Investigation has a 90%+ conviction rate. Your next call is to an attorney.
IRS Whistleblower Defense Tampa
Someone reported you to the IRS for a bounty. You need an attorney.
Trust Fund Penalty Defense Tampa
The TFRP makes you personally liable. Defending requires legal strategy.
Foreign Account Compliance Attorney
FBAR and FATCA carry the highest penalties in tax law.
IRS Examination Attorney Tampa
An IRS examination is the government\'s chance to increase your tax. An attorney controls the scope.
Collection defense
CDP Hearing Attorney Tampa
A Collection Due Process hearing is your right to challenge IRS collection.
IRS Levy Defense Attorney Tampa
The IRS seized your wages or bank account. An attorney can stop and reverse it.
IRS Collection Alternatives Explained
Five paths out of IRS debt. An attorney evaluates all of them.
IRS Hardship Attorney Tampa
When you genuinely cannot pay, the IRS has formal procedures.
IRS Statute Expiration Attorney
The 10-year collection statute is a legal defense.
Relief & resolution
Offer in Compromise Attorney Tampa
An OIC is a legal negotiation with the federal government.
Innocent Spouse Attorney Tampa
Joint returns create joint liability. IRC 6015 provides three forms of relief.
Florida Bankruptcy Tax Attorney
Florida\'s exemptions make bankruptcy a powerful tax elimination tool.
Unfiled Return Attorney Tampa
Unfiled returns create civil and potential criminal exposure.
Business matters
Why an attorney
Free tool
Old tax debt? Bankruptcy may discharge it.
Income tax that clears three timing rules can be wiped out entirely. Run your dates against the rules and see where you stand.
Run the Three-Rule Analysis →Straight answers
Before you call
When do I actually need a tax attorney instead of a CPA?
When the matter is adversarial. Audits with bad facts, criminal exposure, trust fund penalty interviews, appeals, Tax Court deadlines, and anything you would not volunteer to a Revenue Agent. An attorney brings two things no preparer can: privilege over your communications, and the ability to take the case to court — which changes how the IRS negotiates long before any petition is filed.
What does attorney-client privilege cover in an IRS case?
Communications with your attorney made for the purpose of legal advice — and unlike the limited accountant privilege, it survives criminal referral and IRS summons. What you have told your CPA over the years is discoverable. What you tell your lawyer is not.
I received a Notice of Deficiency. How long do I have?
Ninety days from the date the notice was mailed to file a petition in United States Tax Court, and the deadline is jurisdictional — day 91 closes the courthouse door and the tax assesses. If a 90-day letter is sitting in front of you, the calendar is the case. Call now, not next month.
Will my case actually go to trial?
Probably not — and that is the point. The overwhelming majority of Tax Court petitions settle with IRS Appeals or Chief Counsel, because government attorneys weigh the hazards of litigation honestly once a judge is watching. Cases built to be tried are usually the ones that never have to be.
What does a consultation cost?
Nothing, and it is privileged from the first sentence. Bring the notice. You will leave knowing where you stand, what the deadlines are, and what it takes to fix it.
If it’s serious, treat it that way.
Free consultation with a tax attorney — privileged, direct, and ending with a clear assessment of where you stand and what it takes to fix it.
Call (813) 229-7100