Dallas County Tax Fraud Attorney
When Tax Problems Threaten Your Business, Your Livelihood or Your Future, Contact an Attorney
Tax Controversy and Tax Litigation: For high-worth individuals and high-profile privately-held businesses, discretion and confidentiality are of critical importance.
IRS Audits and Appeals: If you have been targeted for an audit, contact a qualified tax attorney before making any contact with the IRS.
- Civil Tax Litigation: If the taxpayer (either an individual or a business) is unable to resolve the initial dispute with tax examiners directly at the administrative level, the next step is typically an IRS appeal. If the matter cannot be resolved satisfactorily to the taxpayer at the IRS Appeals level, the taxpayer has the right to proceed against the IRS in a number of different federal courts.
- U.S. Tax Court Litigation: The majority of cases are heard in Tax Court, before a judge with expertise in tax law.
- U.S. Bankruptcy Court: If the taxpayer has filed for Chapter 7, Chapter 11 or Chapter 13 bankruptcy, a Bankruptcy Court judge can rule on (a) whether IRS deficiency claims and IRS tax liens are valid and (b) whether upheld tax liabilities can be discharged.
- U.S. District Court Litigation: Taxpayers must exhaust all administrative IRS remedies and pay the disputed tax before seeking a District Court remedy (refund).
- U.S. Court of Federal Claims: For substantial tax claims brought by large corporations, the company can pay the tax and then sue for refund of the disputed amount.
- Tax Refund Litigation: Brown, PC is a valuable resource for business owners, professionals and high net-worth individuals facing complex situations involving overpaid taxes, often in connection with business operations.
- Summons Enforcement Proceedings: Mr. Brown's unusual degree of experience resolving tax controversies and representing clients in tax litigation is an asset for an individual or organization facing summons enforcement proceedings.
Criminal Tax Matters: Mr. Brown is adept at strategies to prevent or limit harmful consequences of a criminal investigation or indictment.
- Attempts to Evade or Defeat Tax: From small business owners who are accused of neglecting to report a complete day's cash proceeds each day to multi millionaires who face allegations of hiding assets offshore or committing employment tax fraud, taxpayers charged with attempting to evade or defeat tax collection through illicit methods are at great risk.
- Willful Failure to Collect or Pay Over Tax: Did you engage in "creative bookkeeping" — perhaps fully intending to reimburse the trust fund and pay over the same amount a short time later to the IRS?
- Failure to File, Supply Information or Pay Tax: The key question in these cases is: did you knowingly and willfully fail to file or pay taxes?
- Fraudulent Withholding Exemption Certificate: Employees who overstate their exemptions on W-4 forms and employers who aid and abet these employees in reporting inflated exemptions may be held to be guilty of criminal offenses.
- Fraud and False Statement: Fraud and false statements typically go hand in hand when it comes to lying about taxes.
- Aid or Assist False or Fraudulent Document: You, a tax preparer, tax attorney or bookkeeper — or representative of a mortgage lender, for example, may be charged with a crime because of your role in connection with a tax return.
- Removal or Concealment With Intent to Defraud: Contact an experienced attorney if you are accused of removing or concealing records or other evidence with intent to defraud the IRS.
- Compromises and Closing Agreements: It is a criminal offense to hide, conceal or remove assets in the course of negotiation of an offer in compromise.
- Fraudulent Returns, Statements, or Other Documents: The charge of "fraudulent returns, statements or other documents" may appear to be redundant, overlapping with other similar, specific charges.
- Omnibus Clause: If you have reached the point of being charged with a crime under the omnibus clause, the circumstances of your case may be delicate, detailed and involved.
- Offenses With Respect to Collected Taxes: A successful defense may result in dropping of all charges or reduction of charges.
- Aiding and Abetting: Anyone who assists another in carrying out or committing any tax crime is at risk of being called into question.
- False, Fictitious or Fraudulent Claims: Any criminal charges originating with the IRS are a serious matter.
- Conspiracy to Commit Offense or to Defraud the U.S.: The crime of conspiracy involves an agreement between two or more people to break the law.
- False Statements: In the eyes of the criminal justice system, a false statement often matters more than the actual offense that the lie seeks to cover up.
- Tax Money Laundering: If the IRS has contacted you requesting information and you have been conducting cash transactions in segments, you may be suspected of the crime of tax money laundering.
IRS Collection Matters: As former trial lawyer for the U.S. Department of Justice Tax Division, Lawrence Brown understands the inner workings of the IRS. He understands how to intervene in the early stages of a tax controversy to work out a favorable resolution.
- Installment Agreements: Once an installment agreement is established, the IRS is required by law to stop enforced collection activities, such as levies of wages and bank accounts and property seizures.
- Offer in Compromise: The IRS may accept an OIC when it is unlikely that the tax liability can be collected in full.
- Currently Not Collectible Status: Once an account is placed in currently not collectible status, the IRS will discontinue enforcement action and release any levies already in place.
- Wage Garnishment: Has the IRS garnished (or threatened to garnish) your wages? We can help.
- Payroll Tax Problems: When representing employers in seeking solutions to payroll tax problems, we first work to keep your business open and then work to resolve your tax liability.
- Innocent Spouse Tax Relief: As part of Internal Revenue Service Restructuring and Reform Act of 1998 (RRA 98), Congress changed the Internal Revenue Code to make the process for obtaining "innocent spouse relief" more equitable.
- IRS Liens and Levies: Taxpayers should not waive or forfeit rights without seeking legal advice from experienced counsel.
- Trust Fund Recovery Penalty: the problem can be resolved through IRS administrative appeal procedures; and sometimes, the solution lies in federal court litigation.
- Unfiled Tax Returns: In many cases, if a taxpayer addresses his or her tax problem before an IRS criminal investigation has begun, it is possible to use the IRS's "voluntary disclosure" policy to file missing returns and avoid prosecution.
- Abatement of Penalties: If the IRS determines that failure to pay or failure to file was due to reasonable cause and not willful neglect, the penalty will not be assessed.
- IRS Summons: The IRS's power to obtain records and testimony is based on statutory law, and federal district courts have the authority to enforce an IRS summons.
- Collection Due Process Appeals: Individuals have the right to appeal any tax assessment or to challenge enforcement actions taken by the IRS.
- Independent Contractor Disputes: Businesses' ability to safely and legally contract with independent contractors must pass the test of compliance with state, federal and local laws.
- Constructive Dividends: If the corporate officer is seen as looting the company for his or her personal gain, there is a good chance the IRS will seek a criminal prosecution.
- Tax Penalty Relief: The IRS may abate reasonable penalties when there is good cause.
- IRS Technical Advice Requests: In the course of an IRS audit, agents may have issued a request for technical advice.
- Private Letter Ruling Requests: Preparing your request for a private letter ruling will require detailed descriptions of an array of specific facts.
- IRS Collection: Liens, Levies & Seizures: Individuals as well as businesses may experience total financial collapse in the face of heavy-handed tax collection actions such as levies and seizures.
- Employment Tax Disputes: Questions regarding what to tax, whom to tax and how much to tax can be vexing.
- Worker Classification: The employee versus contractor classification question impacts many aspects of the relationship between the one who pays for the work done and the one who does the work.
- Partnership Tax / TEFRA: The Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) allows the IRS to treat a partnership as a separate taxable entity in most cases for the purposes of audit.
- Valuation Disputes: Valuation questions may be a point of contention in a civil tax audit, a criminal tax investigation or a proposed purchase or sale of a business.
- Fringe Benefits: An IRS tax audit may uncover — or may be triggered by — special factors such as valuation of questionable fringe benefits.
- Officer and Executive Compensation: The IRS often scrutinizes officer and executive compensation closely.
- Reimbursed Expenses: Are auditors alleging that your deducted expenses did not meet the criteria of "ordinary and necessary" ("appropriate and helpful to your trade or business")?
- Trust Fund Recovery Penalties: When you, the employer, withhold funds for taxes from employees' paychecks, you are expected to keep those funds in a trust fund until the time comes to submit those taxes.
- Tip Compliance: The IRS sometimes makes raids upon restaurants and bars to check on what methods management uses to ensure compliance in tip reporting by waiters and waitresses.
A Toll Free Call to Request a Consultation
Contact Brown, PC, located in the Dallas-Fort Worth area in Texas, from anywhere in North America or the world to discuss your tax controversy. Call 888-870-0025 for the sophisticated legal counsel you need regarding your U.S. tax controversy or tax litigation matter.Print this Page