Federal Tax Litigation

Taxpayers receiving IRS deficiency notices have two choices:  Either litigate in the Tax Court and paying the deficiency if they lose their case, or paying the deficiency first, and then suing for a refund in United States District Court. Most taxpayers choose to litigate first in the Tax Court.

Historically, the many judges sitting on the Tax Court have held positions in the government. Although the Tax Court has not earned a reputation of being taxpayer-friendly, the decisions of the Tax Court are generally upheld by the Courts of Appeal. Still, there are times when the taxpayer will be better advised to pay the deficiency and dispute the issue in federal district court in the taxpayer’s circuit.

Whether the taxpayer chooses to litigate in Tax Court or in District Court, our tax-trained attorneys are experienced and ready to handle even the most complex cases.