No one likes a federal or state tax audit. We understand that and the efficient and successful resolution of a tax audit requires skillful representation early in the process. Our primary goal in any tax dispute is to win the case. We assist our clients who are subject to federal and state audits by responding to Information Document Requests, in communicating with IRS agents, and in formulating overall strategies. Our specific role in a particular tax audit depends upon the needs of each individual client and the circumstances of each case. In some audits we play a lead role at the request of the client. In other audits we serve in a purely advisory role, staying in the background with no direct contact with the tax authority, allowing the client’s CPA to handle the matter. Because Attorney Ratner is a CPA, he is able to effectively communicate with the client’s CPA in the language of accountants. We have been involved in and successfully resolved audits involving many different types of businesses and industries. We have addressed and successfully resolved tax issues arising in many different types of situations including issues with respect to economic substance issues, tax accounting issues, independent contractor classification issues and the timing of income inclusion. On a number of occasions, we have resolved the audit with our client obtaining a refund. Our experience encompasses all facets of negotiation with tax authorities including responding to audits, administrative summonses, preparing administrative protests and petitions. We also represent clients faced with demands for documents or testimony in connection with examinations of other taxpayers. From the earliest stages of a dispute or transaction, we always proceed collaboratively with our client, their accountants, and the client’s existing counsel. For decades we have observed that CPAs, as good as they may be, are often unwilling to challenge an audit determination because they lack the knowledge or ability to challenge the determination by way of an administrative appeal or tax court petition. For decades we have observed that the larger the accounting firm, the more timid the accountants are, often limited by firm policies unknown to the client. To the contrary, our reputation is well known to the local IRS personnel and they know we are prepared to take the audit results to the next level. We will not be bullied by an aggressive IRS auditor and they know it.
We represent clients in tax disputes from the audit level through the appellate process and into the court system. We work at local, state and federal levels, and in all types of tax disputes—business tax, employment tax, personal income tax, sales and use tax, estate and gift tax, and controversies under international treaties.