I have spent more than three decades on one side of one kind of fight: taxpayers against the IRS. This site is about the part of that work where procedure decides outcomes: protests to the IRS Independent Office of Appeals, Collection Due Process hearings, and cases in the United States Tax Court.
Admissions
- Licensed to practice law in Florida, Colorado, and Texas.
- Admitted to practice before the United States Tax Court.
- Admitted to the U.S. District Courts for the Middle, Southern, and Northern Districts of Florida, the U.S. Court of Federal Claims, and the U.S. Court of Appeals for the Eleventh Circuit.
Why procedure
The IRS runs on deadlines and documents. A protest filed on day 29 opens a door that is closed on day 31. A Form 12153 sent to the right office stops a levy; the same form sent late gets you a conversation and nothing a judge will ever review. The taxpayers who do well are rarely the ones with the best story. They are the ones who used the right procedure at the right time.
That is what the guides on this site are for. Each one cites the Code section, regulation, Internal Revenue Manual provision, or Tax Court Rule it relies on, so you can check the work.
Counsel, not a call center
Conversations with an attorney for the purpose of legal advice are privileged. That matters before you write a protest, before you sit down with a settlement officer, and before you file anything in Tax Court. Bring the hard facts to the person who cannot be compelled to repeat them. You can read more about that in how privilege works in IRS cases.