Texas Tax Litigation Lawyer on the Forefront of Civil Tax Litigation
By the time a case reaches litigation, the IRS has typically subjected the taxpayer to months or years of audits and procedures. Tax fatigue is common, as is the impression that no favorable end is in sight. In truth, civil tax litigation is an opportunity for a taxpayer to finally obtain relief after a hard-fought battle. Making the right decisions at this crucial stage can drastically change the outcome.
Brown, PC has been on the forefront of tax litigation for a quarter-century and takes a strategic approach to battling the IRS. Attorney Lawrence Brown spent years on the opposite side of the courtroom as a Department of Justice Tax Division trial attorney. Having prosecuted dozens of tax cases, he is intimately familiar with the litigation processes from the DOJ’s perspective. He also has maintained ties to his colleagues that remain at the DOJ and with whom he has a reputation for being an ethical, professional lawyer who aggressively represents his clients’ rights.
Our tax litigation team has taken on challenges that seemed insurmountable and won favorable solutions through perseverance, experience and a passion for justice. We have successfully litigated high-profile, high-stakes cases involving prominent sports, business and entertainment figures and large publicly traded and privately held multinational corporations.
Choosing the Right Forum in a Texas Tax Litigation Case
What we do hinges on where we do it. Choosing the right forum for filing a tax lawsuit is an essential first step in reaching a favorable outcome. Knowing which court is best in a particular case comes only with vast experience. Having tried dozens of high-stakes tax cases, we know the pros and cons of each court and weigh these factors when deciding which forum has the greatest strategic and tactical advantages. We regularly litigate in the four trial-level courts with authority over federal civil tax claims, including:
Based in Washington DC, the U.S. Tax Court hears cases in 74 cities, including Dallas, TX. A specialized tax judge considers the claim in a bench trial. A Dallas tax lawyer at our firm may choose this forum for cases in which the tax liability amount is in dispute, we want to reduce discovery or the issues in the case are too complex to present to a jury or generalist judge.
U.S. district courts sit in 94 judicial districts throughout the country. The authority of these courts arises out of Article III of the U.S. Constitution. Our lawyers consider bringing a claim in this forum if the case issues are not technical in nature, a jury trial is desirable, extensive discovery is beneficial and paying liability before litigation makes sense.
This Washington, DC-based court hears cases involving a monetary dispute between the federal government and other parties, usually regarding a tax matter. We may recommend filing in the U.S. Court of Federal Claims if we do not plan to demand a jury trial, a judge with tax expertize is not necessary, precedent case law is more beneficial to our client, full discovery is disadvantageous or unnecessary, or our client seeks to avoid publicity.
We may recommend filing a Chapter 11 or Chapter 13 bankruptcy petition to release property seized by the IRS, stay IRS collection proceedings, negotiate a reasonable installment period, reduce the overall and installment payment liabilities, shorten collection period and halt further accrual of interests and penalties.
The rules and procedures in each forum are second nature to our Texas tax litigation lawyers after years of intense daily emersion and practice. We can immediately recite the rules of procedures, the judges, the government attorneys, court costs and processes associated with each court. This level of familiarity gives our lawyers an edge because we can anticipate precisely how our actions will play out in a given case. Based upon our comprehensive analysis of the case, we choose the forum that provides the optimal technical and strategic advantage.
Strategic Decisions Reach Optimal Results
Civil tax litigation may be stressful, time consuming, expensive and intrusive. Our firm remains cognizant of costs to our client while recommending expenditures that increase success of the litigation. We move cases forward to reach resolution efficiently and economically, and avoid litigation when possible. However, often litigation is the only means to achieve desired results. When deciding whether to litigate and in which forum, we take a strategic approach, which includes asking the right questions, such as:
- Do the facts support settling the claim under equitable terms?
- Has the IRS agreed to a reasonable settlement or will our client benefit from escalating the claim to litigation?
- Are the facts of the claim highly complex and sophisticated as to warrant a bench trial before a judge who is knowledgeable in tax law matters?
- Are there issues concerning IRS’s reasonableness and justice that might be suitable for a jury trial?
- Should our client litigate the issue before paying the tax liability, or should the client pay liability first?
- Does a detailed pre-trial schedule order and extensive discovery benefit a case or should we minimize these steps to save our client time and money?
- What is the estimated time to fully litigate a case in each potential forum?
Because of our experience and consideration for our clients, tax lawyers, CPAs and other tax professionals often refer complex disputes to Brown, PC. They know that we deliver confidential, personalized, experienced counsel in cases involving sophisticated tax disputes.
Consult with a Knowledgeable Texas Tax Litigation Lawyer to Resolve a High-Stakes Tax Dispute
Often the only way to resolve a tax dispute is through litigation. Texas tax litigation lawyer Lawrence Brown has the experience and knowledge to develop an efficient, strategic plan of action for reaching a favorable result. Brown, PC always views the big picture to protect your legal rights, while mitigating damages to your brand and reputation arising out of a tax claim.