Tax Litigation

There are times when tax controversies cannot be resolved with the Internal Revenue Service or with a state tax authority. The professionals at Andreozzi Bluestein possess extensive experience in litigating tax matters in federal, state, and territorial courts.

Tax Litigation

There are times when tax controversies cannot be resolved with the Internal Revenue Service or with a state tax authority. The professionals at Andreozzi Bluestein possess extensive experience in litigating tax matters in federal, state, and territorial courts.

There are times when tax controversies cannot be resolved with the Internal Revenue Service or with a state tax authority. The professionals at Andreozzi Bluestein possess extensive experience in litigating tax matters in federal, state, and territorial courts.  Firm partner Randy Andreozzi leads the Tax Litigation Practice Group.   Randy is a former National Industry Counsel and Senior Trial Attorney with the United States Department of Treasury.  In that capacity, and now in private practice, he has served as lead counsel on several cases establishing important precedent on Federal tax issues.

Always sensitive to the cost of litigation, we endeavor to work with our clients to effectively and efficiently identify and develop the issues central to the litigation. We focus our efforts on those key issues, often beginning while the audit is still underway, so that we are in a position to facilitate the most favorable pre-trial settlement or, if necessary, to present the strongest case at trial.

Our professionals are uniquely qualified to guide clients through the examination and litigation process with strategic advice and effective legal representation, including:

  • Working with IRS Revenue Agents
  • Responding to Information Document Requests or IRS summonses
  • Requesting technical advice or private letter rulings from the IRS National Office
  • Negotiating settlements and closing agreements
  • Preparing protests and negotiating settlements in the IRS Office of Appeals
  • Identifying the most appropriate judicial forum and strategies for tax litigation
  • Conducting discovery
  • Litigating your case at trial and on appeal

United States Tax Court

This federal court may address tax disputes before the IRS assesses the tax liability.

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United States District Court

Federal tax cases may also be litigated in the United States District Courts.

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United States Court of Federal Claims

The Court of Federal Claims is a special court that hears a variety of claims against the United States, including claims for refund of overpayments of federal taxes.

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State Courts

Disputes relating to state and local taxes are generally litigated in the respective State courts.

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