In audits and appeals cases, our lawyers:
- Help CPA firms develop and present their clients’ cases when audited by the IRS. We also handle IRS audits directly for our own clients.
- File written administrative protests with IRS Appeals if audits are not settled
- Handle audits and appeals against the North Carolina Department of Revenue and other governmental tax agencies in the Southeast
The range of our audit matters include:
- Residency status disputes in state income tax cases
- Innocent spouse tax relief in the context of separation or divorce
- Company share valuations in federal estate and gift tax disputes
- Conservation easement qualification and valuation disputes in IRS audit and appeals
- Reasonable compensation and T&E expense defense in closely held business cases
- Economic substance issues involving sale/leasebacks, mergers, tax losses andpartnership tax controversies