Tax Audits, Workouts and Tax Controversy

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Tax Audits, Workouts and Tax Controversy

Tax Controversy Is Complex—We Know the Way Through It We’re On Your Side—and We Know How to Fight for You

Navigating a tax audit or tax dispute is stressful, but you don’t have to face it alone. At Pinna, Johnston & Burwell, P.A., we bring decades of experience helping individuals and businesses resolve high-stakes issues with the IRS and state tax authorities. Our attorneys have the depth of knowledge and courtroom experience to advocate effectively and creatively on your behalf. Whether it’s an audit, unfiled returns, or litigation in Tax Court, we stand ready to help.

We represent clients at every level of tax controversy, from audit to appeal. Our team has successfully handled federal and state matters involving individual, corporate, partnership, and trust tax issues. We are also deeply experienced in negotiating offers in compromise, penalty abatement, and achieving non-collectible status when appropriate. Whether you’re seeking to clean up past issues or defend your current position, our mission is to resolve matters efficiently and strategically with the least disruption to your life or business.

Trusted by Clients to Resolve Tax Disputes—Big and Small

Tax Audits, Workouts and Controversy

Key Topics and Processes

1. IRS and State Audits

Audits can be intrusive and intimidating, but preparation and representation make all the difference. We help clients respond clearly and legally, minimizing tax exposure and navigating the process with confidence.

2. Tax Debt Workouts

If you owe back taxes, we can help you explore options like Offers in Compromise, installment agreements, or currently not collectible status. Our goal is always to resolve tax debt in the most favorable and realistic way possible.

3. Tax Court and Appeals

When disputes escalate, our attorneys have a successful record before the U.S. Tax Court and state tax authorities. We advocate firmly and persuasively for our clients, often achieving dramatic reductions in tax liabilities.

4. Real Property Tax Disputes

Unfair assessments can significantly increase your tax burden. We’ve helped clients reduce property tax valuations by hundreds of thousands—even millions—saving them significant long-term costs.

Tax Audits, Workouts and Tax Controversy Experts

Why Clients Trust Us with High-Stakes Tax Problems

We bring decades of successful tax resolution experience to the table, with a focus on creative strategy and effective advocacy. Our attorneys are not only licensed to practice before the U.S. Tax Court—they also understand the nuances of IRS procedure and state-level enforcement. We’ve guided clients through sensitive, high-dollar disputes and restored their financial footing. Most importantly, we handle every case with integrity, discretion, and personal attention.

Deep Experience

Our team has over 40 years of combined experience in tax law, IRS negotiations, and Tax Court litigation.

Strategic Solutions

We go beyond forms and formulas—we think strategically to uncover smart, lawful ways to resolve your case.

Full-Service Representation

From unfiled returns to courtroom defense, we’re equipped to handle every aspect of your tax controversy.

FAQ - Tax Audits, Workouts and Tax Controversy

What should I do if I receive an IRS audit notice?

Don’t panic—and don’t ignore it. Contacting our experienced tax attorneys right away can help you avoid missteps. We’ll review the audit scope, gather relevant documents, and represent you throughout the process. A calm, informed response is often the best defense.

Can I really settle my tax debt for less than I owe?

Yes, in some cases. The IRS offers programs like the Offer in Compromise, which allows taxpayers to settle for less based on income, expenses, and assets. However, these offers must be carefully prepared and substantiated. Our firm knows how to assess your situation and prepare a compelling case.

What if I haven’t filed tax returns in years?

You’re not alone—and there are ways forward. We work with clients to gather information, file back returns, and avoid or minimize penalties. Coming forward voluntarily often puts you in a stronger legal position.

Is Tax Court my only option if I disagree with the IRS?

Not always. You may be able to appeal the IRS’s decision within the agency or through state-level processes. However, if litigation becomes necessary, our attorneys are admitted to U.S. Tax Court and have successfully argued cases that saved clients hundreds of thousands of dollars.

How do I know if my property tax assessment is too high?

If you suspect your property value is overstated, you may be overpaying in taxes. We review assessments, obtain independent valuations, and handle appeals to local tax boards or courts. Successful challenges can result in significant tax savings over time.