Tax Controversy Lawyer for IRS Audits, Collections, FBAR and Tax Court Matters

What Is Tax Controversy?

Tax controversy refers to any dispute between a taxpayer and a taxing authority — most commonly the Internal Revenue Service, but also state revenue departments. These disputes can begin with a simple notice questioning a deduction, escalate into a full audit, and, in some cases, proceed to litigation in the United States Tax Court. What starts as a routine inquiry can quickly expand in scope if it is not handled carefully and promptly.

Early legal strategy matters because the IRS operates on strict procedural deadlines, and the way a taxpayer responds in the first 30 to 90 days of a dispute can determine whether the matter is resolved efficiently or becomes a prolonged, costly controversy. A tax controversy lawyer helps taxpayers understand their rights, respond to IRS correspondence appropriately, and position the case for the best realistic outcome — whether that means a full concession, a negotiated settlement, or a determination that litigation is necessary.

IRS Notices and Audit Defense

IRS audits generally take one of three forms: correspondence audits conducted by mail, office audits requiring an in-person interview at an IRS office, and field audits in which an IRS revenue agent examines records at the taxpayer's home or business. Each type carries its own procedures, document requests, and risks.

Anthony Girand Law assists clients who have received IRS notices — including CP2000 notices, examination letters, and requests for supporting documentation — by reviewing the notice, identifying the specific issues raised, and developing a response strategy. This includes organizing records, preparing written responses, and, where appropriate, representing the client directly in communications and meetings with IRS personnel so that the taxpayer is not navigating the process alone.

IRS Collections

Once a tax liability is assessed, the IRS has powerful collection tools at its disposal, including federal tax liens, bank levies, and wage garnishments. These actions can have serious and immediate consequences for a taxpayer's finances and credit.

There are several avenues available to address a collections matter, including installment agreements that allow the liability to be paid over time, currently-not-collectible status for taxpayers experiencing financial hardship, and offers in compromise that may allow a liability to be settled for less than the full amount owed. Anthony Girand Law evaluates each client's financial circumstances to determine which option is realistically available and helps prepare and negotiate the necessary submissions to the IRS.

Penalty Abatement

The IRS assesses a range of penalties, including penalties for late filing, late payment, and accuracy-related errors on a return. In many circumstances, these penalties can be reduced or eliminated through a penalty abatement request.

Common grounds for abatement include first-time penalty abatement for taxpayers with an otherwise clean compliance history, and reasonable cause relief for taxpayers who can demonstrate that circumstances beyond their control — such as serious illness, natural disaster, or reliance on incorrect professional advice — led to the noncompliance. A well-documented abatement request, supported by appropriate evidence, is often the difference between a penalty being upheld or removed.

FBAR and Foreign Account Reporting

U.S. taxpayers with financial interests in, or signature authority over, foreign financial accounts may be required to file a Report of Foreign Bank and Financial Accounts (FBAR), as well as comply with other foreign asset reporting requirements under federal law. Failing to file, or filing incorrectly, can expose a taxpayer to significant civil penalties, and in certain cases, criminal exposure.

A central issue in FBAR enforcement is whether a failure to file was willful or non-willful, because the applicable penalty framework differs substantially depending on that determination. Anthony Girand Law advises clients on FBAR compliance, evaluates exposure under existing disclosure programs, and represents clients in addressing prior non-compliance with foreign account reporting obligations.

Tax Court and Federal Tax Litigation

When the IRS proposes a deficiency, it issues a Notice of Deficiency — often referred to as a "90-day letter" — which gives the taxpayer 90 days (150 days if the notice is addressed outside the United States) to file a petition with the United States Tax Court. Missing this deadline generally forecloses the ability to challenge the deficiency in Tax Court before payment.

Anthony Girand Law represents clients in preparing and filing Tax Court petitions, developing litigation strategy, engaging in settlement negotiations with IRS counsel, and preparing for trial when a resolution cannot be reached. Federal tax litigation requires careful attention to procedure, evidentiary rules, and the substantive tax law at issue.

Business Owners and Entrepreneurs

Business owners, startup founders, independent contractors, and investors frequently face tax controversy issues that are more complex than those of individual wage-earning taxpayers. Payroll tax disputes, worker classification issues, entity-level reporting questions, and multi-year business audits all require an understanding of both tax law and the underlying business operations.

Anthony Girand Law's combined background in law and business allows for practical, informed representation of entrepreneurs and business owners navigating IRS scrutiny of their companies, alongside the firm's broader startup law practice.

Why Work With Anthony Girand Law

Anthony Girand, Esq. holds a JD/MBA and has been a member of the Maryland Bar since 1995, with a federal practice spanning tax controversy, federal litigation, immigration, and startup law. This combination of legal training and business background supports practical judgment in negotiating with the IRS and evaluating the real-world costs and benefits of each available option. As with any legal matter, outcomes depend on the specific facts involved, and no particular result can be promised or guaranteed.