Tax Controversy Services

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.

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