Areas of Practice

IRS Tax Audits

 

Why hire an attorney to represent you during a tax audit? Patricia Carbone will work closely with your accountant to determine the appropriate responses to an audit letter.  When defending an audit, a tax attorney can bring new perspective to your case by analyzing the facts and the law to draft well researched explanations and arguments to submit to the tax agency. If you receive an initial audit result that you do not agree with, you have a limited time to dispute your result by submitting an appeal within the I.R.S. or a petition to the United States Tax Court. An experienced tax attorney can advise you on the potential outcomes of these actions so that you do not miss the filing deadlines and lose your appeal rights. Contact Patricia for a consultation to review your audit and appeal rights.

United States Tax Court

 

Have you received a letter from the IRS titled as “Notice of Deficiency” or sometimes referred to as a 90 day letter? The letter means that you have 90 days from the date of the letter to file a petition with the United States Tax Court. One benefit to filing a petition in the United States Tax Court is that you can dispute the tax assessment proposed by the IRS without having to pre-pay the tax assessment. Patricia can advise and represent you during the process of a Tax Court case.

Tax Collections and Alternatives

 

Have you received a letter or notice from the IRS stating that you owe tax, penalties, and interest for one or more tax years? You do have options for resolving this tax debt, such as negotiating a monthly payment plan called an installment agreement. A tax attorney can also advise you on whether your case may be eligible for other collection alternatives including requesting an offer in compromise, a penalty abatement, currently not collectible status, or innocent spouse relief. Contact Patricia for a consultation to learn more about these alternatives.

Cryptocurrency and FBAR Compliance

 

Do you own cryptocurrency, or have you been involved in cryptocurrency transactions previously? Do you own or control a foreign bank account? Patricia can review your tax filing history and advise you on whether you may need to take additional actions to bring your tax filings into compliance. These may include filing initial or amended tax returns for prior years or applying for a voluntary disclosure with the IRS. Contact Patricia for a consultation to discuss the importance of tax compliance.

Federal Defense

 

There are multiple government agencies that investigate potential tax fraud, mail/wire fraud, health care fraud, and bank fraud. If you or someone you know is contacted by a federal agent, it is important to contact an attorney as soon as possible to protect your rights as a subject, target, or witness in the investigation. Patricia can advise you during the investigation or if charges are filed.