For CPAs & Tax Professionals

When your clients face a substantial tax problem, you need an experienced tax attorney. That’s where I come in.

How We Work Together

You identify the issue. When a client faces an audit, assessment, or investigation that requires an attorney whose practice is dedicated to tax controversy, you make the introduction.

I handle the controversy. I take over all dealings with the IRS or state tax authority—examinations, appeals, litigation, and criminal defense—while you continue serving the client's ongoing tax needs.

We coordinate as necessary. I keep you updated on case developments and consult with you on matters that affect the client's broader tax situation. When appropriate, we work under a Kovel arrangement to extend attorney-client privilege to our communications, protecting sensitive discussions. Your client gets specialized representation without losing the CPA relationship they value.

Common Referral Situations

  • Examinations and Audits

    Representing clients through IRS and state tax examinations from initial contact through closing.

    Managing information document requests, preparing responses, and challenging proposed adjustments.

    Establishing reasonable cause defenses to avoid or reduce penalties.

  • Appeals

    Negotiating settlements with IRS Appeals Officers based on hazards of litigation analysis.

    Presenting legal and factual arguments to resolve disputes without the cost and uncertainty of trial.

    Pursuing Fast Track Settlement and other alternative dispute resolution procedures.

  • Tax Court Litigation

    Challenging IRS determinations in U.S. Tax Court before payment is required.

    Contesting Notices of Deficiency, penalty assessments, and collection actions through CDP hearings.

    Preparing cases for trial, conducting discovery, and presenting evidence and legal arguments.

  • State Tax Controversies

    Defending New York and California residency and domicile audits with multi-million dollar exposures.

    Challenging nexus determinations, jurisdiction claims, and allocation disputes.

    Contesting responsible officer assessments and defending against vigorous state enforcement.

  • Voluntary Disclosures

    Advising clients with unreported income or unfiled returns on whether and how to come forward.

    Navigating IRS voluntary disclosure procedures to minimize civil penalties and avoid criminal prosecution.

    Coordinating parallel state voluntary disclosure programs.

  • Internal Investigations

    Conducting privileged internal investigations of potential tax compliance issues before government contact.

    Responding to whistleblower complaints and investigating accounting or reporting irregularities.

    Advising companies on disclosure obligations while protecting attorney-client privilege.