Tax Controversies

Representing taxpayers in audits, Tax Court and refund litigation, tax shelter disputes, criminal investigations and trials.

Tax controversies are especially sensitive, both because of their complexity and because similar conduct may be treated civilly in some cases and criminally in others. This sensitivity is even more acute in specific areas, such as tax shelters, on which the government focuses as potential areas of abuse. Knowing how to deal with the Internal Revenue Service is critical for the successful resolution of these kinds of tax controversies. We help taxpayers and tax professionals navigate tax controversies.

  • Representing taxpayers in civil audits, including dealing with Revenue Agents and Officers, Appeals Officers and IRS attorneys
  • Representing taxpayers in "eggshell audits," where criminal exposure lurks in the background
  • Dealing with especially sensitive tax problems, such as allegedly fraudulent tax shelters and offshore accounts
  • Representing taxpayers in criminal investigations, including dealing with IRS Special Agents, Tax Division conferences, dealing with federal prosecutors and grand juries
  • Handling all aspects of criminal trials, from indictment through trial and appeals
  • Defending accountants and other return preparers in investigations and prosecutions for aiding and assisting in the preparation of false tax returns, conspiracy and related charges
  • Prosecuting taxpayers' claims in United States Tax and District Courts

Panel Presentations

As tax experts, members of our team have also participated in multiple panel presentations about criminal tax fraud, including:

American Bar Association National Institute on Criminal Tax Fraud

  • Role of the Forensic Accounting During a Criminal Investigation (2006)
  • Electronic Evidence and Discovery (2005)
  • Ethical Problems Facing the Criminal Defense Lawyer (2004)
  • Dealing with the Bureau of Prisons: Preparing a Client for Incarceration (2003)

American Bar Association Tax Section, Committee on Civil and Criminal Tax Penalties

  • Self-Protection for Attorneys: Legal and Ethical Dilemmas in Defending Money Laundering Cases (Spring Meeting, Sept. 13, 2008)
  • Anti-Money Laundering Compliance, Politically Exposed Persons and AML Insurance Regulations (October 21, 2006)

“We bring the best from both worlds — legal and consulting — to every client, every business situation worldwide.” David Axelrod
Axelrod, LLC