Tax Controversy Representation
“Tax controversy” is the legal term for disputes and enforcement matters involving the IRS or other taxing authorities.
Tax Attorney for IRS Audits, Tax Debt and IRS Disputes & Collections.
Jason Kovan is a licensed U.S. Tax Attorney & CPA with over 26 years of tax expertise representing clients around the world.
We represent individuals and businesses across the United States and U.S. taxpayers worldwide in IRS audits, tax debt, IRS collection letters, IRS penalty abatememnt, tax levy, IRS disputes, and other tax controversy matters. Expertise with complex cross-border U.S. tax matters.
Our firm provides tax controversy representation for those real-world situations. As your IRS tax attorney, we help evaluate the issue, identify risks, protect your rights, and develop a response strategy based on the facts of your case.
We represent clients in matters involving:
- IRS audits and examinations.
- Tax debt and collections action.
- IRS penalties and penalty relief requests.
- IRS tax liens and levies.
- IRS notices and disputes.
- Appeals and resolution strategy.
If you are unsure what your IRS notice means or what to do next, contacting an IRS tax lawyer early can help prevent avoidable mistakes.
IRS Audit Attorney and Audit Defense Representation
An IRS audit can feel overwhelming, especially when deadlines are short and the stakes are high. Our firm acts as your IRS audit attorney to help you respond carefully, protect your position, and manage communications with the IRS.
Many audit outcomes are affected by how the case is handled from the beginning. A rushed or incomplete response can create unnecessary risk.
Reviewing the IRS notice and identifying what is being examined.
Communicating with the IRS on your behalf.
Determining what documents and information are actually required.
Organizing records and supporting documentation.
Preparing an IRS response strategy before anything is submitted.
Managing deadlines and follow-up requests.
Protecting Your Position During an IRS Audit
We focus on helping clients respond to IRS inquiries and audits in a way that is accurate, organized, and strategic. That may include:
Narrowing issues where appropriate.
Clarifying documentation before submission.
Avoiding unnecessary over-disclosure.
Addressing penalty exposure early.
Preparing for potential appeal issues if the audit expands or escalates.
Tax Debt Attorney for IRS Collections, Levies, and IRS Payment Solutions.
IRS tax debt can become more serious over time if notices are ignored or handled without a clear strategy. Our firm represents clients as a tax debt attorney in collections matters involving back taxes, enforcement risk, and resolution planning.
IRS tax debt representation - tax debt attorney.
IRS tax debt can become more serious over time if notices are ignored or handled without a clear strategy. Our firm represents clients as a tax debt attorney in collections matters involving back taxes, enforcement risk, and resolution planning.
As your tax attorney we assess IRS debt and exposure.
The amount claimed and tax years involved. The type of notices received.
Immediate collections risks.
Penalty and interest exposure.
Available response and resolution options.
IRS tax debt cases are not all the same. Take yours seriously.
Some require urgent collections defense, while others require a structured negotiation and documentation process.
You should strongly consider speaking with an IRS audit attorney if:
The amount in question is significant.
You own a business or have complex income sources.
The IRS is requesting extensive records.
You are concerned about penalties.
You need to respond or have already responded to the IRS and the issue is getting worse.
You received multiple notices or deadlines.
When to Hire an IRS Audit Defense Attorney
Early legal guidance often improves the quality of the response and the range of available options.
If you are dealing with a levy issue, speaking with an IRS levy attorney quickly is important. Delays can reduce available options and increase financial pressure.
IRS levies.
IRS liens.
Collection notices and enforcement actions.
Bank account levies (if applicable).
Wage garnishment concerns (if applicable).
IRS Collections Defense
As an IRS collections attorney, we represent clients facing or at risk of:
Our role is to evaluate the facts, explain the realistic options, and build a strategy that aligns with your legal and financial situation.
Installment agreements.
Offer in compromise (if applicable).
Penalty relief / abatement requests.
Collection holds or status changes (if applicable).
Appeals or dispute procedures (if applicable).
Resolution Options and Strategy
Depending on your circumstances, resolution options may include:
Common IRS Penalties.
Clients often contact us after receiving notices involving:
Failure-to-file penalties.
Failure-to-pay penalties.
Accuracy-related penalties.
Other IRS penalties related to compliance or reporting (if applicable).
IRS Penalty Abatement Attorney for Penalty Relief and Defense
IRS penalties can substantially increase the total amount owed. In some cases, relief may be available depending on the facts, timing, and documentation.
Our firm represents clients as an IRS penalty abatement attorney in matters involving penalty defense and requests for relief.
We help clients evaluate whether there may be a basis to request relief, including:
First-time penalty relief / administrative relief (if applicable).
Reasonable cause arguments.
Supporting documentation and explanation.
Procedural response and follow-up.
Penalty Relief and Abatement Strategies
Penalty relief is case-specific.
If penalties are a major part of your case, working with an IRS penalty abatement attorney can help ensure the issue is evaluated and presented properly.
Speak With an IRS Tax Attorney About Your Audit, Tax Debt, or IRS Dispute.
If you are facing an IRS audit, tax debt, penalties, or collections action, early action can help protect your options. Our firm provides professional tax controversy representation designed to help clients respond strategically and move toward resolution.
Confidential inquiry. Clear next steps. Representation for individuals, businesses & organizations.
Why Work With an IRS Tax Attorney Don't Handle the Matter Alone.
IRS matters often involve legal, procedural, and strategic decisions that can affect the outcome. Even before a dispute becomes formal, what you say, submit, or delay can matter.
Working with an IRS tax attorney can help you understand what the IRS is asking and why.
Respond strategically instead of reactively.
Avoid preventable mistakes that may expand the issue.
Protect your rights during audits and collections action.
Organize complex facts and documentation.
Coordinate a consistent plan across audits, tax debt, penalties, and disputes.
Tax Attorney vs CPA When You Have IRS Disputes.
CPAs and tax attorneys may both play an important role, but their roles are not identical. In many IRS dispute matters — especially audits, collections, and contested issues — clients seek legal representation to help manage risk, strategy, and communications.
If your case is complex, escalating, or involves multiple tax years/issues, it is often worthwhile to speak with a tax attorney about next steps.
Tax Controversy and IRS Representation for Individuals and Businesses
Our firm represents a wide range of clients facing IRS tax controversy issues.
Individuals:
IRS audit notices | Tax debt and collections action | Penalties and disputes | Multi-year tax issues.
Business Owners:
Business tax audits | Payroll tax concerns | IRS notices and collections matters | Owner and business tax controversies.
Professionals, Self-Employed, and High-Complexity Cases:
Complex income and deduction issues | Recordkeeping/documentation disputes | Multi-source income matters | Strategic audit and dispute response.
International Clients:
U.S. tax controversy matters involving international facts | Cross-border issues requiring coordinated tax representation.
What to Expect When You Contact Our Law Firm
Initial Case Review
We review your IRS notice, deadlines, and the basic facts of your matter to understand what type of issue you are facing (audit, tax debt, collections, penalties, or another dispute).
Strategy and Scope
We identify the immediate priorities, discuss potential options, and explain the scope of representation based on your situation.
IRS Representation
If we move forward, we handle communications, responses, submissions, and strategy related to your IRS matter in accordance with the engagement.
Resolution and Next Steps
We work toward a practical resolution and help you understand the next steps to remain compliant and reduce future risk.
Please fill in your name, mobile number and email address.
Here are our discussions, news updates and blogs.
FAQ About IRS Audits, Tax Debt, and Tax Controversy
Not every audit requires legal representation, but many do — especially if the amount at issue is significant, the IRS is requesting extensive records, or you are concerned about penalties or disputed positions. Speaking with an IRS audit attorney early can help you assess risk and avoid a response that weakens your position.
An IRS tax attorney helps evaluate the legal and procedural issues in your IRS matter, develop a response strategy, communicate with the IRS, and represent you in audits, collections, penalty matters, and other tax disputes. The exact role depends on the type and stage of the case.
Yes. A tax debt attorney can help assess the IRS collections issue, identify immediate risks, and evaluate possible resolution strategies. If you are facing levy action or serious collections notices, speaking with an IRS collections attorney or IRS levy attorney promptly is important.
In some cases, yes. Penalty relief depends on the facts, the type of penalty, timing, and supporting documentation. An IRS penalty abatement attorney can evaluate whether there may be a basis for relief and help prepare a response or request.
That depends on the nature of the matter. Some issues are primarily accounting/compliance matters, while others involve disputes, legal strategy, audit defense, collections, or potential escalation. If the matter is complex or contested, many clients choose to consult an IRS tax attorney.
You should review and respond to IRS notices as soon as possible. Deadlines can affect your options, and delays may increase penalties, collections risk, or procedural complications. If you are unsure how to respond, contact a qualified IRS tax lawyer promptly.
Tax controversy is the broader legal term for disputes and enforcement matters involving the IRS, including audits, penalties, appeals, and collections. Tax debt defense is one part of tax controversy, focused specifically on balances owed, collections actions, and resolution options.