Tax Controversy & Federal Defense
High-stakes representation for complex federal tax disputes, administrative appeals, and U.S. Tax Court litigation support.
U.S.D.C.
Federal Strength
Tax controversy is the intersection of technical tax law and strategic legal defense. When the IRS issue a Notice of Deficiency or a multi-million dollar assessment, the standard 'audit defense' approach is no longer enough. You require specialized counsel who can navigate the administrative appeals process and prepare your case for potential litigation in the U.S. Tax Court.
Our Tax Controversy practice provides institutional-grade defense for corporations and high-net-worth families facing high-stakes examinations. We specialize in the forensic documentation of 'reasonable cause' and the technical rebuttal of IRS positions, ensuring your capital is protected by the full weight of the Internal Revenue Code.
How we deliver this service.
A rigorous, phase-driven process ensures nothing is missed and every position is defensible.
Case Forensic Audit
We perform a ground-up forensic audit of your tax history and the specific triggers that led to the federal dispute.
Technical Strategy Design
Our senior practitioners design a multi-layered defense strategy, identifying every statutory and case-law defense available.
Evidence & Evidence Gathering
We compile the documentary evidence and expert testimony required to substantiate your positions and rebut IRS assumptions.
Administrative Appeals
We represent you in the IRS Office of Appeals, utilizing 'hazards of litigation' to secure favorable administrative settlements.
Tax Court Petitioning
For unresolved disputes, we coordinate the filing of U.S. Tax Court petitions to halt collection and force a technical review.
Final Case Resolution
We manage the final settlement negotiations, ensuring all agreed-upon adjustments are technically accurate and closed for good.
Litigation Support
The Final Defense Against a 90-Day Letter.
Receiving a Statutory Notice of Deficiency (the '90-day letter') is the start of a countdown. Within 90 days, you must either pay the tax or file a petition with the U.S. Tax Court. We specialize in preparing the technical petitions required to move your case out of the local examination office and into the hands of the IRS Chief Counsel's office.
By petitioning the Tax Court, we stop all IRS collection actions and force a more senior-level review of your case. This strategic 'escalation' often results in settlements that were simply not available at the field agent level, protecting millions in family and business capital.
Litigation focus: U.S. Tax Court Petitions, Notice of Deficiency resolution, Counsel-level settlement negotiations, and trial readiness.
Tailored for every client profile.
Penalty Abatement
Technical Rebuttal of Accuracy-Related Penalties.
The IRS routinely assesses 'Accuracy-Related' penalties (IRC § 6662) that can add 20% to 40% to your tax liability. Our practice specializes in the technical defense against these penalties by establishing 'Reasonable Cause' under IRC § 6664. This involves proving that you acted in good faith despite an error, often through reliance on qualified tax advice.
We provide the forensic proof required to meet the 'Qualified Professional' reliance test, systematically stripping away assessed penalties and ensuring that your tax obligation is limited to the statutory minimum, not a punitive fine.
Defense focus: IRC § 6662 penalty mitigation, Section 6664 reasonable cause petitions, and Form 843 penalty abatement requests.
Personal Liability
Defending Against Personal Tax Liability.
One of the most aggressive federal enforcement tools is the 'Trust Fund Recovery Penalty' (Section 6672). It allows the IRS to pierce the corporate veil and hold officers or employees *personally liable* for unpaid payroll taxes. If you receive a Letter 1153, you are at risk of losing personal assets for a corporate debt.
We defend 'Responsible Persons' by challenging the IRS's definition of willfulness and personal authority. We manage the administrative protest process to prevent the assessment of these personal liabilities, providing a critical shield between your corporate operations and your personal net worth.
Enforcement focus: Letter 1153 defense, Section 6672 personal liability mitigation, and responsible person technical audit.
Facing a federal tax dispute?
Don't confront the IRS Chief Counsel without technical defense. Secure a professionale controversy strategy to protect your capital and your rights.
Specific deliverables, precisely documented.
“Controversy is about authority and evidence. We ensure your tax positions are defended with technical rigor and delivered with institutional strength.”
Technical clarifications.
Answers to the most frequently asked questions about how this service works in practice.
A Statutory Notice of Deficiency (90-day letter) is the IRS's final legal determination of your tax debt. You must file a Tax Court petition within 90 days to stop the assessment and collection.
Related services.
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Email Us
hello@jaguartax.comLondon Headquarters
123 King Street
Mayfair, London W1J 8AA
United Kingdom
San Francisco
555 California Street, Suite 5000
San Francisco, CA 94104
United States
New York
350 Fifth Avenue, 59th Floor
New York, NY 10118
United States