Federal Tax Controversy
We've resolved over $2.1 billion in federal tax disputes.
Exposed position?
Let's assess yours in 90 seconds. If we identify no actionable strategy, the consultation costs nothing.
Admitted before the U.S. Tax Court · DOJ Tax Division · IRS Office of Appeals
Our Guarantee
If our assessment finds no actionable path to reduce your liability, you pay nothing.
Most tax attorneys charge for the consultation before they know if they can help you. We don't. We've resolved over two billion dollars in disputes because we only take positions we believe in.
Outcomes above are anonymized and represent actual matters closed 2019–2025. Individual results vary based on facts, jurisdiction, and IRS discretion.
How We Work
Three phases. No surprises.
Assessment
Understand every exposure before the IRS does.
We map your full tax position — open years, unreported income, penalty exposure, and statute of limitations windows. Within 48 hours you have a written memo quantifying your risk and ranking your options.
- Written risk memo
- Liability quantification
- Options ranking
- Statute analysis
Strategy
A position built for the specific examiner, not a template.
We draft your response, prepare substantiation, and select the correct procedural pathway — whether that's audit reconsideration, an offer in compromise, voluntary disclosure, or Tax Court petition. No two strategies are identical.
- Procedural pathway selection
- Substantiation preparation
- IRS response drafting
- Settlement modeling
Resolution
Closed file. Documented outcome. No open exposure.
We negotiate directly with revenue agents, appeals officers, and DOJ Tax Division attorneys. We don't settle until the number reflects what the facts actually support — not what the IRS opened with.
- Direct IRS negotiation
- Appeals representation
- Closing agreement review
- Post-resolution compliance
Courts & Jurisdictions
U.S. Tax Court
Regular & Small Tax Case Division
U.S. Court of Federal Claims
Tax Refund Litigation
DOJ Tax Division
Civil & Criminal Tax Matters
IRS Office of Appeals
All 50 States
FBAR / FinCEN
Offshore Disclosure & Penalties
9th, 5th & 2nd Circuits
Federal Appellate Courts
No-Cost Assessment
Your exposure deserves a precise answer, not a retainer.
Five questions. Ninety seconds. If we find no path to resolution, there's no charge — and no pressure.