We represent clients in a variety of matters and at various stages of litigation, such as:

IRS Audits and Examinations - we represent clients during IRS audits of their business, individual, and estate tax returns. 

State Audits and Examinations -  we represent clients during audits conducted by various state taxing authorities, such as the Department of Revenue, Labor & Industries, and Employment Security.

IRS Appeals - when taxpayers wish to challenge the findings of an IRS audit, we represent clients at IRS Appeals.  This typically requires preparing a formal protest setting forth the relevant facts and legal authority supporting the taxpayer’s position, and then conducting negotiations with IRS Appeals. 

IRS Voluntary Disclosures - we advise clients on the risks and benefits of participating in the IRS's Voluntary Disclosure Program, and assist them in navigating and complying with its requirements.  The program intends to eliminate the risk of criminal prosecution for taxpayers who voluntarily come forward and disclose prior tax reporting issues or unfiled tax returns.  The Offshore Voluntary Disclosure Program also provides for reduced civil penalties for those taxpayers who disclose previously undisclosed offshore accounts and unfiled FBAR returns. 

United States Tax Court - if taxpayers have received a Notice of Deficiency, or are unsatisfied with the result at Appeals and wish to pursue their case in court, we represent clients in the Tax Court. 

United States District Court - taxpayers may decide to pursue their case in district court, either after receiving a Notice of Deficiency or a denial of a claim for refund.  We represent clients in federal courts across the United States, not just in Seattle. 

United States Courts of Appeal - we also represent clients at the United States Courts of Appeal, and the Supreme Court.  If either party (the taxpayer or the government) is dissatisfied with the result in the Tax Court or the US District Court, an appeal to the Circuit Court may be made.  Our lawyers brief and argue the cases before the court. 

Claims for Refund - if taxpayers believe they have made an error on previous returns which has resulted in an overpayment to the IRS, we assist clients by filing a claim for refund and representing them during any examination of the claim by the IRS. 

Estate Tax Returns - we represent and advise estates in filing the federal and state Estate Tax Returns.  There are a number of issues that can arise in connection with preparing the return such as valuing an ongoing business and other assets, determining allowable deductions, and addressing issues of unpaid taxes, among others. 

Criminal Tax Defense - we represent clients who have been charged with committing federal tax crimes, such as tax evasion and filing false returns.  We also represent clients during all stages of a criminal tax investigation, including the Grand Jury investigation, which are typically conducted by Special Agents assigned to the IRS’s Criminal Investigation division.  This is an important process as the potential exists to resolve the case before the government seeks an indictment.

Expert Witness - our lawyers have served as expert witnesses on tax law in criminal and civil cases. 

Tax Opinions - we also provide tax opinions, typically at the request of accounts or lawyers, with respect to reporting positions on a tax return or the tax consequences of contemplated transactions.