Tax Dispute Representation
Audits & Investigations
For most individuals and businesses, the first hint of any IRS issue is the little letter informing them that they are being audited. In a difficult economy, the government usually steps up in their efforts to find any irregularities in tax returns. Christina represents taxpayers during audits and deals directly with IRS agents, responding to their requests, advocating for no change, and negotiating a favorable settlement. In addition to being an attorney, Christina has a degree in Accounting. Christina is very comfortable with accounting concepts and believes that your accountant can and, sometimes, should play a key role in your tax resolution. Where appropriate, Christina is happy to work with other professionals in order to achieve time and cost efficiency. If a matter is not resolved in the audit level, Christina handles administrative appeals with the IRS to obtain highly favorable settlements – and many times full IRS concessions – for her clients.
Appeals
When an agreement cannot be reached at the audit level, Christina would take the matter to the Appeals level. As a private attorney for many years, and then as IRS counsel, Christina has worked very closely with many IRS Appeals Officers and has an excellent rapport with many of them, often reaching a speedy and favorable resolution. By being organized, thorough, and having good follow through, Christina has gained the trust and confidence of many IRS Appeals Officers, agents, and counsel alike. She will be able to present your case in the best light possible.
Tax Court Litigation
Sometimes a settlement cannot be reached despite diligent efforts on both sides. When the IRS issues a Notice of Deficiency, the taxpayer has 90 days in which to file a Petition before the United States Tax Court. Christina is very familiar with the practice and procedure of the Tax Court and can best strategize her clients’ cases before the Tax Court.
Criminal Investigation
When the federal government pursues perceived egregious irregularities in the criminal arena, it is important for taxpayers to retain an attorney who can rigorously defend these matters. Christina has successfully represented taxpayers in these criminal investigations and has been able to resolve these matters without escalating actions.
Collections
- Offers in Compromise
- Installment Agreements
- Hardship Deferrals/Currently Non Collectible
- Penalty Abatement
- Wage & Bank Account Levies
- Lien Subordination
