Federal Tax Controversies
The Andersen Tax controversy practice assists clients with the resolution of disputes that result from federal and state tax return examinations.
Our professionals have years of controversy experience dealing with a wide range of federal and state tax issues for both individual and business entity taxpayers. Complex regulations coupled with increased enforcement by IRS present a substantial need for clients to have a trusted and experienced tax controversy resource. Our team adds value over the full lifecycle of taxation, from planning and reporting through examination defense and dispute resolution. Our controversy professionals work closely with Andersen Tax subject-matter specialists to ensure that the right combination of tax technical expertise is paired with a thorough understanding of tax practice and procedure to secure optimal outcomes for our clients. Our tax controversies professionals can assist you with:
Federal and State Examinations
- Representation before IRS or state tax authorities, including coordination of meetings and discussions with examiners from early stage notices through final closing agreements
- Formulation of responses to IRS Information Document Requests (IDRs) or state inquiries
- Analysis and technical research supporting tax positions
- Interest recovery with respect to proposed assessments
- Voluntary disclosure and amnesty programs
- Pre-filing agreements and other alternative dispute resolution strategies
- Schedule UTP filings and related disclosure statements
- ASC 740 reserves analysis for uncertain tax positions
- Preparation of tax protests and representation at IRS Appeals Office or state tax appellate authority.
- Rendering of expert testimony, computational and tax technical analyses in support of tax litigation.
Partners in Creating Value
Andersen Tax knows that the best way to avoid controversy is to plan for it. Our controversy practice interacts with local client service teams on a regular basis, inviting local teams to involve the controversy practice before tax returns are filed and exam notices are sent. Often times, disputes can be avoided through good documentation and the development of fact patterns that support favorable tax positions. Andersen Tax controversy professionals include former government attorneys who provide a critical review of return positions and substantiation requirements before disputes arise with federal or state tax authorities. Whenever possible, Andersen Tax adds value to clients by resolving potential controversies before they materialize.
Jeff R. Malo
New York, NY
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