High-Stakes Tax Controversy Representation: IRS Audits, Appeals, Tax Court, and Large-Dollar Debt Resolution

As a CPA and Michigan attorney admitted to practice before the United States Tax Court since 1999, my tax controversy work focuses exclusively on high-value disputes and complex IRS matters. These cases typically involve more than $500,000 in controversy, and often include sophisticated issues related to real estate, business entities, investment portfolios, and multi-year assessment problems.

My tax controversy practice is built around four core areas of representation: IRS Audits, IRS Appeals, U.S. Tax Court Litigation, and large-dollar IRS Collection Defense. I also represent clients facing serious FBAR and international reporting penalties.

I have experience in handling cases for high-net-worth individuals, business owners, estates, trustees, and family offices. If you are experiencing a tax dispute, contact our office today to discuss the details of your case.

IRS Examinations & High-Dollar Audits

IRS audits involving more than $500,000 require a level of strategy, documentation, and tax law fluency that goes far beyond routine exam defense. As both a CPA and attorney, I manage these cases from the moment the IRS contacts you through the final audit determination.

Common issues I handle include:

  • Real estate basis and capital gain disputes
  • Rental property losses and passive activity classification
  • S-corporation income and distribution
  • Business deductions and depreciation
  • Substantiation disputes involving multi-year items
  • High-income individual audits
  • Trust, estate, and fiduciary tax audits

For clients with significant complexity—multiple entities, long depreciation histories, or large carryforwards—early strategy often determines the entire outcome. My approach is proactive and focused on preventing an audit from escalating unnecessarily.

IRS Appeals Representation

(For amounts in controversy exceeding $500,000)

If an IRS audit results in an unfavorable outcome, the next step is the IRS Independent Office of Appeals, where most high-dollar cases can still be resolved without litigation.

I handle all aspects of the Appeals process, including:

  • Preparing formal written protests
  • Developing factual records and legal arguments
  • Presenting “hazards of litigation” positions
  • Negotiating settlement terms
  • Challenging penalties, including accuracy and fraud
  • Appeals involving rejected installment agreements or collection alternatives

Because Appeals is independent from the audit division, this is often where strong legal and financial analysis—combined with Tax Court-oriented negotiations—can significantly reduce the amount owed.

U.S. Tax Court Litigation

I have been admitted to practice before the United States Tax Court since 1999 and represent clients with substantial amounts at stake who need judicial review of an IRS position.

Cases I handle in Tax Court include:

  • Deficiency disputes involving large, proposed assessments
  • Real estate valuation issues
  • Complex partnership and LLC allocation cases
  • Challenges to disallowed deductions or carryforwards
  • Capital gain and basis disputes
  • Cases involving penalties and the IRS burden of proof
  • Collection Due Process (CDP) matters involving levies and liens

Tax Court allows for litigation without paying the disputed tax first, making it the venue of choice for taxpayers facing large assessments. My litigation strategy is built on meticulous preparation, understanding of the factual accounting details, and command of the tax law issues that drive the case.

High-Dollar Tax Debt Resolution & IRS Collections Defense

(For amounts in controversy exceeding $500,000)

When substantial tax debts have already been assessed—whether through audit, late filings, payroll issues, or multi-year liabilities—the IRS moves into aggressive collection mode. For clients with six- and seven-figure liabilities, the objective is to stop enforced collection and negotiate a workable resolution.

I represent clients in:

  • Complex installment agreements and negotiated payment plans
  • Partial-pay installment arrangements
  • Offers in Compromise (when legally appropriate and strategically beneficial)
  • IRS lien and levy defense
  • Collection Due Process (CDP) litigation
  • Penalty abatement based on reasonable cause
  • Trust Fund Recovery Penalty (TFRP) cases

These cases often require deep financial analysis, documentation of income and asset structures, and a long-term tax strategy that aligns with the client’s broader estate or business plan.

FBAR & International Reporting Penalty Defense

For high-net-worth individuals with foreign financial accounts, assets, or entities, the IRS may assert severe penalties for alleged non-compliance with FBAR (FinCEN Form 114) or other foreign reporting requirements.

I represent clients facing:

  • Willful and non-willful FBAR penalty assessments
  • Multi-year penalty stacking
  • Reasonable-cause challenges
  • Appeals of FBAR determinations

Focused on High-Value, High-Complexity Tax Controversy Matters

My tax controversy practice is intentionally narrow, and only in the categories above. This allows me to apply the full depth of my CPA background, Audit Defense experience, and knowledge litigating matters in my law practice.

If you are in need of tax controversy representation, please contact our office today to discuss the details of your case and learn how I can help.