Practice Areas > TAX LITIGATION

Tax Litigation (Civil)  – The firm handles all types of civil tax litigation in all
federal courts and in all California Courts, at both the trial and appellate levels.

• Tax litigation in the U.S. Tax Court, including:
  • 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 U.S. Bankruptcy Courts, including:
  • Section 505 actions to determine tax liability
  • Objections to claims by tax agencies
  • Dischargeability litigation involving tax liabilities
• Tax litigation in Superior Court, including refund litigation, residency litigation, wrongful levy litigation