Awards & Recognition
The Tax Law Offices of David W. Klasing
Navigating the intricacies of the tax system can be a daunting challenge, as tax disputes are an inherent aspect of this complex landscape. While many tax disputes can be resolved through agreements or administrative settlements, there are situations where the only viable option for a taxpayer to achieve a favorable result is to engage in tax litigation. The sheer complexity of tax laws and the potential consequences of failing to resolve disputes appropriately highlight the importance and necessity of tax litigation. Taxpayers must understand the gravity of these situations and their potential impact on their financial well-being.
Hence, having the expertise of renowned Panorama City Tax Attorneys alongside you becomes indispensable to navigating this challenging terrain and achieving a desirable resolution. At the tax law offices of David W. Klasing, our highly-skilled dual-licensed Attorneys and CPAs possess a wealth of substantive knowledge and tax court experience. Our team is well-versed in handling tax cases across various forums, including the U.S. Tax Court, the U.S. Court of Federal Claims, Federal District Court, and Bankruptcy Court.
Additionally, we will help you interact with numerous tax agencies, such as the Internal Revenue Service (IRS), the California Franchise Tax Board (FTB), the Employment Development Department (EDD), and the California Department of Tax and Fee Administration (CDTFA). We are dedicated to thoroughly reviewing your case and examining your tax returns and other financial records to assess your rights and options. We also guide clients through IRS or state tax audits, addressing any notice of deficiency received. We will explore the merits and strengths of your case to help you contest a deficiency, pursue a refund, or manage other potential tax disputes.
Out of an estimated 1.1 million attorneys and 560,000 CPAs in the country, only 24,000 are both attorneys and CPAs. David W. Klasing has earned a master’s degree in taxation and is among an exclusive group of approximately 3,000 professionals in the country with similar credentials. This unique background sets our team apart from the rest, enabling us to deliver unparalleled services and support to you. Moreover, we have a proven track record of success. To date, we have never “lost” in tax court. Our commitment to excellence is unwavering – if we do not believe we will win, we will not take your case.
Is Tax Litigation Right for You?
When faced with a tax dispute, it’s essential to determine whether tax litigation is the best course of action for your specific situation. This decision involves thoroughly understanding the tax litigation process and carefully evaluating the potential benefits and risks of pursuing this route.
Understanding the Tax Litigation Process: Tax litigation is a legal process that typically begins when a taxpayer cannot resolve disagreements with a tax authority through administrative settlements, agreements, or appeals. At the end of an examination, if the IRS proposes any changes, the taxpayer receives an examination report outlining these changes and a letter notifying them of their right to appeal within 30 days. The appeal process usually involves a conference with an IRS Appeals Officer and filing a formal written protest detailing the disputed changes and the reasons for disagreement.
If the taxpayer does not respond to the 30-day letter or fails to reach an agreement with the IRS Appeals Office, they will generally receive a notice of deficiency, which provides a 90-day window to file a petition with the U.S. Tax Court. Failure to respond to this 90-day letter would result in assessing the amount on the notice of deficiency, even if the proposed changes were made in error. Tax litigation can be lengthy and demands that the taxpayer presents a solid case to persuade the court that the tax authority’s decision or action is incorrect.
Tax litigation may be considered in the following situations:
- When all administrative remedies have been exhausted without a satisfactory resolution, leaving litigation as the last available recourse for a taxpayer to address their tax dispute;
- If tax authorities have misapplied the law or misinterpreted the facts, the taxpayer can present a solid legal argument to support their stance;
- In cases where the financial stakes are substantial and the potential benefits of litigation justify the associated costs and risks;
- When a taxpayer seeks to challenge the constitutionality or fairness of a specific tax policy or regulation that affects them adversely;
- If there is a need for judicial clarification due to conflicting tax laws or regulations, leading to uncertainties in the proper application or interpretation of these provisions; or
- When a taxpayer aims to contest unjust or disproportionate penalties or other enforcement actions levied against them by the tax authorities.
Before deciding to pursue tax litigation, weighing this legal process’s potential benefits and risks is essential. Some benefits of tax litigation include the following:
- Tax litigation provides an opportunity to challenge and correct erroneous tax assessments or decisions tax authorities make;
- Successful litigation may result in recovering substantial amounts of overpaid taxes, reducing your financial burden;
- Litigation can lead to setting legal precedents that benefit other taxpayers facing similar tax disputes;
- Tax litigation helps protect your rights as a taxpayer by addressing and resolving disputes arising from unfair or unjust tax enforcement actions; and
- Skilled tax litigation attorneys can negotiate settlements or payment plans, potentially reducing penalties and interest charges.
Audits and Internal Appeals: Exploring alternative dispute resolution options, such as audits and internal appeals, is essential before resorting to tax litigation. These methods can be less adversarial, expensive, and often quicker than litigation. If a satisfactory resolution can be achieved through these avenues, pursuing them may be more advantageous than engaging in a potentially lengthy and costly court battle. Audits involve a detailed examination of your tax returns and financial records by the tax authority. If discrepancies or issues are found, we will help you resolve them through discussions and negotiations with the relevant tax agency.
Internal appeals allow taxpayers to contest a tax authority’s decision without litigation. There are generally two types of internal appeals:
- Expedited appeals process: This accelerated approach aims to resolve tax disputes by assembling the auditor, their manager, and an appeals officer to review and settle the case jointly. The process may be less effective due to the auditor’s and manager’s emotional investment in the audit results. As they have been directly involved in the initial audit, they may be more inclined to defend their findings, which could introduce bias in the decision-making process and impact the objectivity of the outcome.
- Regular appeals process: Initiated by filing a tax court petition, this process allows for an independent review by an appeals officer not involved in the initial audit, excluding the IRS auditor and their manager from direct involvement. The appeals officer will consider the taxpayer’s arguments and evidence and attempt to resolve them while considering the hazards of litigation for the IRS. If an agreement is not reached, the taxpayer has another chance to appeal with the IRS Chief Counsel’s office on the Tax Court steps.
It is never a wise idea to try to represent yourself at Tax Court or to put your case in the hands of anyone but experienced dual-licensed Tax Attorneys and CPAs like us at the Law Offices of David W. Klasing. Our skilled professionals know the lay of the land in appeals, in front of the Chief Counsel’s Office and Tax Court, and can help you negotiate a reasonable settlement without going through the hassles of a trial. Our extensive experience handling both IRS and California state tax audits and internal appeals has allowed us to resolve tax disputes without ever stepping foot in tax court, sparing our clients the most expensive part of litigation.
With a 98% settlement rate, the IRS also prefers to avoid litigation. If we believe the appeals and litigation process can benefit you, we will take your case and strive for the best possible outcome. However, we will not take the case if we determine that pursuing these options is not in your best interest. Our primary goal is to ensure that you are treated fairly by the taxing authorities, and we will always prioritize your needs above our own. Regardless of the tax issue you face, be it an offshore asset matter, voluntary disclosure, IRS audit, or dispute with a state or local taxing authority, our team is well-equipped to provide the highest caliber tax litigation defense.
Tax Litigation and Tax Controversy
Tax litigation and controversies commonly involve tax disputes that arise between taxpayers and federal or California tax authorities. These disputes can involve various parties, such as businesses, trusts, estates, and individuals. Tax-related disagreements can emerge from multiple tax categories, including income tax, estate, and California state sales and use tax. Typically, tax disputes are classified into civil and criminal tax matters.
Civil Tax Controversies: When facing civil tax controversies, taxpayers deal with complex and nuanced tax laws and regulations. In these situations, the expertise of tax attorneys becomes invaluable, as they can help clients navigate the intricacies of tax law, collaborate with revenue agents, strategize audits, and pursue administrative or judicial appeals. Their roles can vary from providing representation in court proceedings to advising taxpayers or their accountants and assisting in planning transactions to prevent future disputes.
Civil tax matters generally start with audit, assessment, and collection activities conducted by a taxing authority, or they might be triggered by a taxpayer seeking a refund. To resolve a civil tax controversy at the federal level, it may be necessary to engage in discussions with the IRS, submit a written appeal to and negotiate with the Appeals Office, or litigate the case in the United States Tax Court, District Courts, or Court of Federal Claims. A similar process exists for handling civil tax controversies at the California state level.
Civil tax controversies can extend to international transactions, where an international tax attorney’s expertise is essential. We are a team of Tax Attorneys and CPAs in a law firm experienced in international tax law so you can count on our experience and knowledge. We will help resolve issues in cross-border activities, navigate complex international tax laws, and plan transactions to minimize tax liabilities. We also assist taxpayers in using voluntary disclosure programs to prevent or reduce tax penalties by disclosing unreported foreign assets or income, demonstrating compliance, and mitigating risks.
Criminal Tax Controversies: Criminal tax controversies encompass cases where taxpayers face allegations of intentional tax evasion, fraud, or other deliberate violations of tax laws. These cases can lead to substantial fines, penalties, and even imprisonment if the taxpayer is found guilty. In criminal tax matters, the government must establish the taxpayer’s guilt beyond a reasonable doubt, which is a higher burden of proof than in civil cases. At the tax law offices of David W Klasing, we play a crucial role in representing taxpayers during criminal tax investigations conducted by the IRS, the Department of Justice, and California taxing authorities throughout criminal trials, sentencing proceedings, and appeals.
In addition to the core services provided in criminal tax controversies, we also help clients by advising on preventative measures and compliance strategies to reduce the risk of future criminal tax issues. Moreover, we work closely with other experts, such as forensic accountants, to build a robust defense and challenge the evidence presented by taxing authorities. Our team boasts first-hand experience with tax litigation cases, having been associated with the top international tax defense law firm of Marc Schwartz. This invaluable background, coupled with our extensive knowledge and expertise, allows us to provide exceptional legal representation for your tax disputes. Our expertise in navigating the complex legal landscape of criminal tax matters is essential for taxpayers facing potential criminal charges or investigations.
How a Dual-Licensed Panorama City Tax Litigation Attorney and CPA Can Help You
At the Law Offices of David W. Klasing, our Panorama City dual-licensed Attorneys and CPAs are renowned for the expertise and achievements in tax law. Consistently ranked as one of the nation’s top tax law firms, our team is recognized for its leadership and authority in the field, as demonstrated by numerous awards, rankings, media mentions, and leadership positions. David W. Klasing, an Attorney-CPA with a Master’s in Tax, has held prestigious positions such as the Past Chair of the OCBA Tax Committee, Past Chair of the California Bar Tax Procedure and Litigation Committee, and Past Education Chair of the American Society of Attorney-CPAs.
While many general litigation firms may offer high-quality representation, they often lack detailed knowledge of tax law and procedures for handling complex tax disputes. At the Law Offices of David W. Klasing, our dual-licensed Attorneys and CPAs focus exclusively on tax litigation and controversies, providing an unparalleled depth of expertise in resolving issues such as offshore asset matters, voluntary disclosures, IRS audits, and disputes with federal or California state taxing authorities. When you choose our Panorama City tax litigation team, you can trust that you are working with dedicated professionals who understand tax law and procedure nuances. Our commitment to providing the highest caliber tax litigation defense ensures that your case is handled with the utmost care and expertise, positioning you for the best possible result.
As a conscientious team of Panorama City dual-licensed Tax Litigation Attorneys and CPAs, we prioritize your needs over ours. If we believe your case cannot be improved through litigation or at the federal or California taxing authority’s internal appeals level, we will not accept your case. Our primary objective is ensuring fair treatment by federal and California taxing authorities, not prioritizing our financial interests. With our team by your side, you can have confidence in receiving the support and guidance necessary to navigate tax litigation and secure a just outcome. For a reduced-rate initial consultation, call our office today at 805-200-4053 and 800-681-1295 or contact us online. Our Panorama City office is conveniently located:
14500 Roscoe Blvd, 4th Floor, Panorama City, CA 91402, United States
