Segal, Cohen & Landis, P.C.
Complex Tax Controversy — Attorney-Led Dispute Resolution
IRS tax attorneys — Beverly Hills, CA. National representation.
Tax controversy encompasses the full spectrum of disputes between taxpayers and federal or state tax authorities — from a simple correspondence audit to multi-year Tax Court litigation involving millions of dollars in disputed tax.
At Segal, Cohen & Landis, tax controversy is our entire practice. We do not offer tax preparation, tax planning, or general accounting. Every case in our firm involves a taxpayer with an active IRS or state tax dispute that requires legal strategy, advocacy, and resolution.
How We Help
Our Approach to Tax Controversy Attorney
IRS and State Audit Defense
Full representation in federal and California state tax examinations — correspondence, office, and field audits. We control scope, manage document production, and present the strongest possible defense of your return positions.
IRS Appeals Representation
IRS Office of Appeals handles the majority of tax disputes before they reach Tax Court. Our attorneys prepare comprehensive legal briefs for appeals officers and negotiate outcomes.
Tax Court Litigation
When administrative resolution is not possible or acceptable, we represent clients in U.S. Tax Court — the specialized federal court with jurisdiction over tax disputes.
Multi-Year IRS Dispute Resolution
Taxpayers with accumulated issues spanning multiple years and multiple tax types need coordinated representation that addresses all issues in a coherent strategy.
How It Works
The Resolution Process
Case Assessment
We review all relevant tax years, notices, assessments, and prior interactions with the IRS to develop a complete picture of the dispute.
Strategy Development
We identify the strongest legal and factual positions, assess the risk of litigation versus settlement, and recommend a resolution path.
Administrative Resolution
Most disputes resolve at the audit or appeals level. We pursue the best available administrative resolution before recommending litigation.
Litigation if Required
If litigation is necessary to achieve a fair outcome, we are fully prepared to take the matter to Tax Court or other appropriate federal tribunal.
Ready to Resolve Your Tax Problem?
Our attorneys have helped thousands of clients resolve IRS matters. Your consultation is free and confidential.
Common Questions
Frequently Asked Questions
What is U.S. Tax Court?+
The U.S. Tax Court is a specialized federal court with exclusive jurisdiction over deficiency cases. Uniquely, you can petition Tax Court before paying the disputed tax. This makes it the primary forum for most contested IRS issues.
When should I hire a tax attorney instead of a CPA for a tax dispute?+
Legal representation is particularly important when a dispute involves litigation, possible criminal exposure or complex legal issues. Attorney-client privilege may protect confidential communications made to obtain legal advice, subject to applicable law and exceptions. It does not automatically protect every document or message sent to the firm. Certain non-attorney tax advice may receive limited statutory protection, but that protection is narrower and does not extend to criminal tax matters.
Related Tax Services
Further reading
Beverly Hills · Los Angeles · National
Segal, Cohen & Landis, P.C.
9100 Wilshire Boulevard, 601 East Tower, Beverly Hills, CA 90212
Free Confidential Consultation