Litigation

Request a Consultation

Tax Solutions

Sometimes the IRS simply won’t budge, and litigation becomes necessary to protect your rights. While fewer than 1% of tax disputes reach trial, having an attorney prepared to litigate strengthens your negotiating position throughout the administrative process. The IRS takes cases more seriously when they know you’re prepared to go to court.

Choosing the Right Court

Tax Court offers a unique advantage: you can contest the IRS’s determination without paying the disputed tax first. Tax Court judges specialize in tax law, and simplified ‘small tax case’ procedures apply when $50,000 or less is at stake. For many taxpayers, Tax Court is the most practical option.

District Court requires you to pay the disputed tax first, then sue for a refund—but it offers jury trials and broader legal principles beyond technical tax regulations. The Court of Federal Claims also requires prepayment but may offer strategic advantages based on circuit precedent.

The Power of Being Litigation-Ready

Even if your case never reaches trial, being prepared to litigate transforms how the IRS handles your case. Appeals officers prioritize ‘docketed’ cases—those already on the Tax Court calendar. Filing a petition often sends cases to Appeals for settlement discussions, creating negotiation opportunities that wouldn’t otherwise exist.

How I Handle Tax Litigation

My litigation approach begins with comprehensive case development—gathering documentation, researching legal issues, and building the strongest possible arguments. I prepare cases as if they’re going to trial, which often produces favorable settlements before we ever see a courtroom.

Attorney-client privilege protects your litigation strategy, and I can represent you in all federal courts that hear tax cases. Understanding procedural rules, evidence requirements, and persuasive legal arguments gives you the best chance of success whether your case settles or proceeds to trial.

Why Choose Boss Tax Law

I’ve been on both sides of tax controversies—first as an IRS agent, now as a defender of taxpayers. This perspective helps me anticipate IRS arguments and develop effective counter-strategies. I dedicate my entire practice to tax disputes, giving me deep expertise in the procedures and strategies that matter most.
If you’re considering tax litigation or want representation prepared to go the distance, contact Boss Tax Law today.