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Tax Controversy


Marcum’s Tax Controversy Services Group specializes in teaming with businesses, their attorneys and accountants to satisfy unresolved tax disputes with Federal, State and local jurisdictions.  The Group members employ extensive experience in selecting the strategies that are essential in obtaining the most favorable results.

Counsel can be faced with complex civil or criminal tax issues involving the Internal Revenue Service requiring the assistance of an accountant or enrolled agent. Our Tax Controversy team can work with counsel to efficiently resolve complex matters to provide a clear assessment of a client's complex tax issues. With our in-depth knowledge of IRS practice and procedures, we can assist clients to efficiently resolve difficult IRS matters.

Marcum’s Tax Controversy Services include:

  • Audit Defense Services
  • Offer in Compromise
  • Responsible Party Assessment Defense
  • Deferred Payment Arrangements
  • Penalty Abatement Requests
  • Releases of Liens and Levies
  • Litigation Support
  • IRS Tax Audit Representation or Consulting
  • Voluntary Disclosure Consulting
  • Amended Tax Return Consulting and Assistance
  • IRS Service Center Matters

Collection Actions, including installment agreements and offers in compromise

  • Tax Controversy Settlement (e.g. Claims and Penalties)
  • Audit Appeal Services

Pre-examination services

  • Monitor the investigative steps of the Special Agent. Many deviations from established procedure can preclude prosecution by the Department of Justice.
  • Make pertinent inquiries of the Special Agent to understand the nature of the investigation.
  • Attempt to mirror the IRS investigation in order to determine what evidence has been documented.
  • Identify procedural and evidentiary problems based on the progress of the investigation. Often, problems can be identified based on investigative steps or inactivity by the Special Agent.
  • Evaluate the client's financial and income tax situation and assess his or he risk of referral for criminal investigation.
  • Understand IRS policies and procedures and monitor the actions of IRS to assess the ongoing risk of a criminal referral.
  • Develop strategies to minimize the possibility of a criminal referral, while at the same time, avoiding actions that might enhance a criminal case should a referral be submitted.

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