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IRS Representation & Tax Controversies

Providing Clarity to Complex Issues

Receiving a letter from the Internal Revenue Service with notification of an upcoming audit or dealing with persistent collections calls from the IRS can be nothing short of heart stopping. At Citrin Cooperman, we understand this – and we can help.

Our team of experts is comprised of seasoned attorneys, certified public accountants, international tax specialists, and former IRS agents who have decades of experience dealing with sensitive and complex tax situations. With a wealth of insight regarding IRS internal policies and procedures, and an in-depth understanding of the tax code, we will help you navigate through a sea of uncertainty and negotiate the best resolution for your case.

Whether you have a complicated dispute or examination, are struggling to satisfy unpaid tax liabilities, or require an expert witness, our individualized approach has consistently produced favorable outcomes and closure for our clients, across a range of industries and around the globe.

We have participated in representative engagements involving:

  • Audits of individual, payroll, estate, corporate & partnership returns
  • Amended/delinquent individual, payroll, estate, corporate & partnership returns
  • Domestic and Offshore Voluntary Disclosures
  • Foreign bank account reports (FBAR)
  • Current FinCEN Form 114a, Electronic Report of Foreign Bank Account
  • Foreign Account Tax Compliance Act (FATCA)
  • Collection information statements; Forms 433A, 433B & 433F
  • Offers in compromise (doubt as to collectability or liability)
  • Installment agreements
  • Abatement of penalties - reasonable cause statements
  • Failure to file, pay, and deposit penalty negotiations
  • Tax liens & levies
  • Substitute for returns filed by IRS
  • IRS appeals
  • Civil fraud penalty protests
  • Expert witness testimony
  • Whistleblower claims
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