Our transactional tax attorneys provide counsel to individuals, small business owners, to large corporate clients and other business entities, private funds, nonprofit organizations, and multigenerational family businesses. Our skilled Tax team brings strategic legal solutions to the tax challenges our clients experience. In addition to assisting clients with income tax questions, our tax team also advises clients on important non-income tax questions, including those involving withholding, excise tax, sales and use tax, gross receipts tax, franchise tax, and property tax issues. The diverse background of our practitioners has encouraged specialized experience with tax issues in the formation, operation, sale purchase and liquidation of business entities, tax issues in divorce, and tax issues in bankruptcy.
Our tax attorneys also handle tax controversy, dispute resolution, voluntary tax disclosure agreements, tax litigation and tax appeals at both the federal and state levels.
Sandberg Phoenix’s tax controversy attorneys work closely with clients to resolve these matters efficiently and strategically. Some disputes can be resolved during the initial stages of an audit with the Revenue Agent, while others may require representation before IRS Appeals or litigation in Tax Court. Our attorneys have extensive experience securing favorable outcomes at every stage of the tax controversy process.
Our team also understands the warning signs that may indicate a parallel criminal tax investigation during an audit. In those situations, experienced counsel is essential. When criminal issues arise, our attorneys have successfully guided clients through resolutions, including achieving the termination of criminal investigations.
Our tax attorneys have successfully defended both federal and state criminal tax cases, including where taxpayers are facing charges of tax evasion and tax fraud. In several of those criminal tax cases, our attorneys have been able to negotiate plea deals, resulting in probation instead of potentially lengthy prison sentences.
Most recently, our team secured a “no change” result in a BBA partnership audit in which the IRS initially assessed an imputed underpayment of nearly $1 million. Although the BBA partnership audit regime has been in place for several years, these audits are only beginning to increase. If your partnership is facing an audit, our attorneys understand the complexities of the BBA audit rules and are prepared to provide experienced representation.
Our attorneys are also skilled negotiators who routinely obtain favorable tax settlements with the Internal Revenue Service (IRS) and the state Departments of Revenue. We have represented clients in a variety of civil and criminal, federal, and tax controversy issues, including:
- Appraiser penalties
- Audit examination negotiation/representation
- BBA partnership audits
- Collection matters
- Employment tax (trust fund penalty)
- Estate and gift tax
- Excise tax
- Franchise/corporate tax
- Income tax (individual and corporate)
- Innocent spouse relief
- IRS Appeals
- Judicial review of administrative assessments
- Non-filer compliance
- Penalty abatement
- Property tax
- Refund claims
- Sales/use tax
- Tax Court litigation
- Tax evasion
- Tax fraud
- Tax preparer penalties
- Valuation issues
- Voluntary disclosures
Reach out to us for a variety of services including: