Tax Controversy and Litigation

Minns & Arnett works with clients through each stage of the process, from administrative audits up to and including litigation in federal court. It is our goal to prevent civil tax controversies from becoming criminal matters (or to quickly resolve civil tax controversies resulting from criminal tax matters).

Minns & Arnett offers clients the following solutions with civil tax matters:

  • Audit Representation – Minns & Arnett prefers that their clients not have any direct contact with the IRS. The firm handles all aspects of the audit process. If Minns & Arnett cannot resolve contested issues during the audit process, the firm will take the controversy before the United States Tax Court, United States Court of Federal Claims, or a United States District Court. Minns & Arnett has litigated and tried hundreds of cases nationwide with outstanding results.
  • Protection Against Levies, Wage Garnishments and Asset Seizures – Minns & Arnett will inform clients of asset protection options available, and negotiate aggressively on their behalf to remove and/or modify an IRS wage garnishment, stop asset seizures and IRS auctions, and release federal tax liens.
  • Requests for Innocent Spouse Relief and Appeals – If one spouse is wrongly burdened with tax liability through fault of their other half, such as unknown tax fraud, Minns & Arnett will work hard to reach a swift resolution for the innocent spouse to be relieved of liability.
  • Tax Court Litigation – Minns & Arnett has nearly 40 years of experience successfully litigating tax controversies in all four federal courts having jurisdiction to resolve tax controversies: The United States Tax Court, The United States District Court, The United States Bankruptcy Court, and the United States Court of Claims.
  • Mediation in the IRS Appeals Division – Minns & Arnett will represent clients before the appeals board and negotiate with the IRS appeals officer, regardless of who handled the original audit. No matter the amount, the firm will conduct a full review of the client’s financial statements and other documentation and utilize the Freedom of Information Act (FOIA) to request the IRS's information on the client’s case.
  • Claims for Refund and Tax Refund Litigation – Minns & Arnett has successfully litigated numerous refund suits both in federal district courts and in the Court of Federal Claims.
  • Trust Fund Recovery Penalty Investigations and Appeals – Minns & Arnett has successfully defended many individuals against IRS imposition of the Trust Fund Recovery Penalty.
  • Preparer/Promoter Penalty Investigations and Appeals – Minns & Arnett has extensive experience representing tax preparers. The firm is also experienced at resolving complex tax disputes involving tax shelter promoter investigations. The firm works diligently to minimize penalties or help clients avoid them altogether.
  • Preparing Offers in Compromise – Minns & Arnett will prepare all IRS forms, assemble backup documentation, and conduct all negotiations with the IRS.
  • Penalty and Interest Abatement – Minns & Arnett will negotiate to reduce the amount of interest or penalty owed the IRS.
  • Negotiating Payment Plans – Minns & Arnett will negotiate payment plans with the IRS for clients who are not able to pay off their full tax debt at once.
  • Foreign Bank Account Reporting Issues – Minns & Arnett understands the requirements of the 2011 Offshore Voluntary Disclosure Initiative and can assist clients in avoiding the harsh consequences, including stiff penalties and criminal prosecution, that can result from an improper disclosure.
  • Payroll Tax Resolution – Minns & Arnett has helped business owners nationwide resolve their payroll tax debt problems and protect the future of their companies.