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Tax Controversy Services
Tax Controversy Services
In times of trouble, turn to a powerful resource.
Overview
Whether you have already received a notification from a taxing authority or think you could be at risk, prompt action is crucial to achieving a positive outcome. Friedman will help you minimize risk and resolve tax controversies optimally, safely and efficiently.
Friedman LLP's Tax Controversy Services Group takes the helm to help you work through a host of complex issues — from corporate and individual income taxes to payroll, sales, and use taxes — in a timely and results-focused manner.
How can we help you?
Leveraging expertise honed over decades in both domestic and international tax controversies, we devise sophisticated strategies to help you resolve disputes. Going a step further, we work with our firm’s transactional and planning professionals to minimize tax in prior noncompliant years and going forward. Our tax controversy services include:
- Responding to all types of tax notices, including those involving unreported income, noncompliance penalties, collection activity, refunds, state residency, and nexus issues
- Defending against IRS and state taxing authority audits and examinations involving income tax, estate and gift taxes, payroll taxes, and sales tax
- Pursuing administrative appeals and other options to resolve audit, deficiency, collection, penalty, and delinquent election issues
- Remediating noncompliance through a variety of procedures
- Structuring and resolving collection issues through offers in compromise and installment agreement payment plans
- Obtaining or seeking reinstatement of tax-exempt status for private foundations and public charities
- Pursuing Technical Advice Memoranda and Private Letter Ruling requests
Rely on Friedman as your first line of defense. To learn more, connect with a member of the Tax Controversy Services team or contact us.
Service Menu
Call on Friedman’s Tax Controversy professionals for assistance with a variety of complex issues:
- Audit examinations
- Audit reconsideration (Audit Recon)
- Collection due process (CDP) hearing requests
- Communication and negotiation with taxing authorities
- Deferred payment arrangements
- Delinquent FBAR submission procedures
- Delinquent international information return submission procedures (DIIRSP)
- Domestic and offshore voluntary disclosure procedures (VD & OVDP)
- Freedom of Information Act requests (FOIA)
- Innocent spouse relief
- IRS appeals
- NYS Bureau of Conciliation and Mediation Services (BCMS) proceedings
- Offers in compromise (OIC)
- Penalty abatements
- Private Letter Ruling (PLR) requests
- Qualified amended returns (QAR)
- Release of collection liens and levies
- Responsible party determination challenges
- Streamlined domestic and foreign offshore procedures (SDOP & SFOP)
- Tax-exempt status
- Technical advice memoranda (TAM) requests
Insights & Events
- April 29, 2022 When the IRS makes unreported income assertions
Doesn’t seem fair, but the Internal Revenue Service (IRS) generally enjoys a presumption of correctness as to matters asserted in...
Read more - October 28, 2020 Tax Planning Guide 2020 - 2021
During these unprecedented times, wise tax planning can provide much-needed financial relief to individuals and businesses. To help you make...
Read more - January 1, 2020 2019-2020 Tax Guide
The elimination of familiar tax planning strategies under the Tax Cuts & Jobs Act (TCJA) in addition to potential changes...
Read more - November 13, 2018 Tax Guide 2018-2019
Concerned how the latest tax developments may impact your 2018 tax strategies? As you head into your 2018 tax planning, this...
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- April 29, 2022 When the IRS makes unreported income assertions
Doesn’t seem fair, but the Internal Revenue Service (IRS) generally enjoys a presumption of correctness as to matters asserted in...
Read more - October 28, 2020 Tax Planning Guide 2020 - 2021
During these unprecedented times, wise tax planning can provide much-needed financial relief to individuals and businesses. To help you make...
Read more - January 1, 2020 2019-2020 Tax Guide
The elimination of familiar tax planning strategies under the Tax Cuts & Jobs Act (TCJA) in addition to potential changes...
Read more - November 13, 2018 Tax Guide 2018-2019
Concerned how the latest tax developments may impact your 2018 tax strategies? As you head into your 2018 tax planning, this...
Read more - February 22, 2018 [Video] New Tax Code, New Strategies Seminar
Gain the knowledge you need to reap tax benefits and avoid pitfalls in the wake of the most significant overhaul to...
Read more - November 9, 2017 House Tax Reform Bill: Digging Below the Surface to Reveal Critical Analysis
By now, you’ve seen media headlines covering the House Tax Reform Bill introduced on November 2. What you may not...
Read more - November 6, 2017 Download Tax Reform White Paper Now!
As Washington takes up the mantle of tax reform, Friedman LLP proudly releases a timely study featuring insights gleaned from a...
Read more - October 3, 2017 Highlighting the Unspoken in the September Tax Reform Framework
This exclusive Tax Alert provides expert insights on critical areas not mentioned in the President's recently released tax reform framework....
Read more - September 28, 2017 White House Tax Reform Framework Released
The White House released its promised tax reform agenda, known as the “September Framework.” While longer than the previous version,...
Read more - June 1, 2017 U.S. Tax Court Ruling in Employee Misclassification Case
IRS must reveal workers’ tax return information in misclassification case A recent unanimous ruling by the U.S. Tax Court could make...
Read more - May 3, 2017 Survey Reveals Businesses Using Independent Contractors May be at Risk for Taxes and Penalties
Clients frequently ask, "What are my chances of being audited?” The answer varies by taxpayer type (business or individual), income...
Read more - April 1, 2017 Special Tax Reform Series
As Washington takes up the mantle of tax reform, Friedman LLP proudly releases a timely series of insights gleaned from...
Read more - February 9, 2016 Employee or Independent Contractor – An Old Question Revisited
Perhaps nothing causes more consternation among small and mid-sized business owners than the employee versus independent contractor problem. Generally, the...
Read more - May 14, 2015 State Tax Issues Caused By Federal Tax Audits
For most businesses, the likelihood of being audited by the Internal Revenue Service (IRS) is less than 2%, but ask those who have been through one and the response is always the same – it is a long, gut-wrenching process, no matter how good your records are.
Read more - March 24, 2015 Real Estate Transfer Taxes in New York
Real estate transfer tax is a tax imposed by states, counties and municipalities for the privilege of transferring real property within a jurisdiction. The tax is sometimes referred to as real estate conveyance tax, mortgage transfer tax or documentary stamp tax, among other terms.
Read more - November 5, 2014 Second Homes In New York May Have Severe Tax Consequences
The New York State and New York City tax laws have numerous traps for unwary nonresidents. To avoid one of the biggest tax hazards, nonresidents owning or renting homes within New York must be aware of the applicable residency tests and what records they should maintain to avoid a dual residency determination. Nonresidents of New York State are only taxed on income earned in or sourced to the state. New York City only taxes city residents. However, if a nonresident is not attentive to the residency tests, the tax consequences can have New York State, and possibly New York City, seeking to impose tax on all income, including interest, dividends, and capital gains, regardless of its source.
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- June 15, 2017 9th Annual Tax Controversy Forum | June 15-16
Friedman’s Dave Shuster will be presenting at this year’s NYU School of Professional Studies’ Annual Tax Controversy Forum. The Tax...
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