U.S.D.C.
Federal Strength
Tax controversy is where technical tax law meets legal defense. When the IRS issues a Notice of Deficiency or a multi-million dollar assessment, standard audit defense is no longer enough. You need counsel who can work the administrative appeals process and prepare your case for potential litigation in the U.S. Tax Court.
Our Tax Controversy practice defends corporations and high-net-worth families in these examinations. We document reasonable cause thoroughly, rebut IRS positions on the technical merits, and use every protection the Internal Revenue Code gives you.
How we deliver this service.
A rigorous, phase-driven process ensures nothing is missed and every position is defensible.
Case Review
We review your tax history from the ground up, along with the specific triggers that led to the federal dispute.
Defense Strategy
Our senior practitioners build the defense, identifying every statutory and case-law argument available to you.
Evidence Gathering
We compile the documentary evidence and expert testimony needed to substantiate your positions and rebut IRS assumptions.
Administrative Appeals
We represent you in the IRS Office of Appeals, arguing the 'hazards of litigation' to reach a favorable administrative settlement.
Tax Court Petitioning
For unresolved disputes, we coordinate the filing of U.S. Tax Court petitions to halt collection and force a technical review.
Final Case Resolution
We handle the final settlement negotiations, check that the agreed adjustments are accurate, and close the case for good.
Litigation Support
What to do with a 90-day letter.
A Statutory Notice of Deficiency (the '90-day letter') starts a countdown. Within 90 days, you must either pay the tax or file a petition with the U.S. Tax Court. We prepare the petitions that move your case out of the local examination office and into the hands of the IRS Chief Counsel's office.
Petitioning the Tax Court stops all IRS collection actions and forces a more senior review of your case. That escalation often produces settlements that were simply not available at the field agent level.
Litigation focus: U.S. Tax Court Petitions, Notice of Deficiency resolution, Counsel-level settlement negotiations, and trial readiness.
Tailored for every client profile.
Penalty Abatement
Rebutting accuracy-related penalties.
The IRS routinely assesses accuracy-related penalties (IRC § 6662) that can add 20% to 40% to your tax liability. We defend against them by establishing 'Reasonable Cause' under IRC § 6664: proving that you acted in good faith despite an error, often through reliance on qualified tax advice.
We assemble the proof required to meet the 'Qualified Professional' reliance test and work through the assessed penalties one by one, so your obligation is limited to the tax itself rather than a punitive fine.
Defense focus: IRC § 6662 penalty mitigation, Section 6664 reasonable cause petitions, and Form 843 penalty abatement requests.
Personal Liability
Defending against personal tax liability.
The Trust Fund Recovery Penalty (Section 6672) is one of the harshest federal enforcement tools. It allows the IRS to pierce the corporate veil and hold officers or employees personally liable for unpaid payroll taxes. If you receive a Letter 1153, your personal assets are at risk for a corporate debt.
We defend 'Responsible Persons' by challenging the IRS's findings on willfulness and personal authority, and we run the administrative protest process to keep these personal liabilities from being assessed. That is the shield between your corporate operations and your personal net worth.
Enforcement focus: Letter 1153 defense, Section 6672 personal liability mitigation, and responsible person technical audit.
Facing a federal tax dispute?
Don't face the IRS Chief Counsel without technical defense. Get a controversy strategy that protects your capital and your rights.
Specific deliverables, precisely documented.
“Controversy comes down to authority and evidence. We defend your tax positions with both.”
Technical clarifications.
Answers to the most frequently asked questions about how this service works in practice.
A Statutory Notice of Deficiency (90-day letter) is the IRS's final legal determination of your tax debt. You must file a Tax Court petition within 90 days to stop the assessment and collection.
Yes. In most cases, we use the Tax Court petition as a tool to move the case to the Office of Appeals or IRS Counsel, where we can reach a negotiated settlement before a trial ever occurs.
Reasonable Cause is the primary defense against tax penalties. It requires proving that you acted in good faith despite an error, often due to reliance on a professional or a complex misunderstanding of the law.
Standard tax debts belong to the corporation. 'Trust Fund' debts (like payroll withholding) can be assessed personally against individuals, which is why they call for immediate professional defense.
From petition to resolution, a case can last 12 to 24 months. The collection stay provided by the petition protects your assets for the entire duration of the dispute.
Related services.
Two Tax Systems, One Team
Email Us
hello@usukcrossbordertax.comLondon Headquarters
4 Crown Place
London EC2A 4BT
United Kingdom
Manchester
CORE
Brown St, Manchester M2 1DH
United Kingdom
San Francisco
600 California St
San Francisco, CA 94108
United States
New York
33 Irving Pl
New York, NY 10003
United States