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Federal & State Tax Litigation

Our highly competent attorneys handle all types of civil tax litigation in all federal courts and in all state courts, at both the trial and appellate levels including:

Tax litigation in the U.S. Tax Court, such as:

  • Deficiency litigation involving income taxes, estate and gift taxes and other types of taxes over which the Tax Court has jurisdiction
  • Innocent spouse litigation
  • Worker classification litigation (independent contractor vs. employee)
  • Collection due process cases

Tax litigation in U.S. District Courts, including:

  • Refund litigation involving income taxes, estate and gift taxes, employment taxes, penalties, and “responsible person” penalty assessments
  • Defense of suits to foreclose tax liens
  • Defense of suits to reduce assessments to judgment
  • Civil forfeiture proceedings under Title 31 (structuring of cash bank deposits)
  • Defense of summons enforcement proceedings
  • Wrongful levy actions

Tax litigation in Superior Court, including:

  • Refund litigation,
  • Residency litigation, and
  • Wrongful levy litigation