Luke Ryan, Esq.

When the IRS questions your tax return, you need an advocate who understands both the technical tax issues and how to negotiate effectively with revenue agents and appeals officers. I represent individuals and businesses through every stage of the audit process, from initial information requests through administrative appeals, working to minimize adjustments and avoid penalties.

When the IRS issues a Notice of Deficiency or you are facing a collection matter, Tax Court may be your best option to challenge the government's position. I handle cases in U.S. Tax Court, presenting evidence and legal arguments to protect clients from unjustified tax assessments and penalties.

A criminal tax investigation is one of the most serious threats an individual or business can face. I defend clients under investigation by IRS Criminal Investigation, the Department of Justice, and U.S. Attorney’s Offices, as well as those who have been indicted for tax crimes.

New York and California tax agencies are among the largest and most serious in the nation. I represent clients in audits, residency disputes, responsible person assessments, and appeals before state agencies and administrative tribunals in both jurisdictions.

If you have unreported income or unfiled tax returns, coming forward voluntarily can be the difference between civil penalties and criminal prosecution. I help clients navigate the IRS's voluntary disclosure programs and similar state programs.

When a company discovers potential tax compliance issues a prompt internal investigation can prevent government enforcement action. I conduct privileged investigations to assess exposure, remediate problems, and advise on disclosure obligations while protecting the company's legal position.

How the IRS Independent Office of Appeals resolves most tax disputes through negotiated settlements based on hazards of litigation, without requiring taxpayers to go to court.

How to challenge, reduce, or eliminate IRS penalties through reasonable cause defenses, first-time penalty abatement, and procedural challenges to supervisory approval requirements.

How U.S. Tax Court litigation works, from filing a petition through trial and appeals, and why most cases settle before reaching a courtroom.

How New York and California determine tax residency and what recent cases reveal about the enforcement tactics both states use to challenge domicile changes.