Tax Litigation and Controversy
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“I like to pay taxes. With them I buy civilization.” — Oliver Wendell Holmes, Jr.

The United States government has just cut taxes by $1.7bn dollars and then to prevent an economic catastrophe, funded the United States with $4bn dollars.

Someone will have to pick up the tab.

The Internal Revenue Service is focused on early issue identification and coordinated enforcement to generate revenue.  This tally is not a political statement, this enforcement is a fact of life.  People will have their houses liened, the accounts levied, and passports revoked by an agency underfunded, and understaffed, and that is still sorting through a year of mail sitting in tractor-trailer trucks.

State and local taxing authorities are escalating their efforts to ensure the collection of all due revenue from parties within their jurisdictions. The states are not only pursing income tax matters, but sales and use tax and corporate franchise tax debts.  Individuals and companies must involve skilled and experienced tax lawyers at the outset of a potentially costly or sensitive tax controversy under these circumstances.

At Brinen & Associates, we counsel clients on tax procedures, including reporting and disclosure requirements, avoiding or abating tax penalties levied by the Internal Revenue Service and the state taxing agencies with whom our clients interact. We monitor and keep clients informed of developments in tax law administration at the federal, state and local levels, such as changes in the audit process, the emergence of new dispute resolution tools and novel caselaw and rulings that may affect clients.

We represent clients on all types of tax deficiencies and refund claims involving income taxes, payroll taxes, excise taxes, franchise taxes, estate and gift taxes, property taxes, sales and use taxes, and related penalties and interest. Our objective is to resolve each client’s tax dispute as quickly and efficiently as possible.

When we undertake a matter, we do the following:

  • Get to know the client, its officers and owners to provide effective representation;
  • Understand the tax problem – the cause and the current state of the problem;
  • Based on understanding of the client and the problem, Brinen & Associates works with the client to determine the most effective procedural route – settlement, conference, administrative hearing, offer in compromise or litigation – to resolve the matter in the most effective and efficient manner possible;
  • Guide the controversy through the process of administrative appeals and/or litigation when issues cannot be resolved at the audit level;
  • Change the business process that created the controversy from the outset;
  • Assist in the compliance efforts going-forward.

Brinen & Associates knows how to work within the federal and state tax systems. We also work closely with Chief Financial Officers, accountants and outside auditors of our clients to ensure that all bases are covered properly and defended during the audit and litigation process.