Audit Representation
As a result of the decades of prior government experience members of our firm possess, including employment in the IRS Audit Division, as well as IRS Counsel’s Office, Andreozzi Bluestein LLP is extremely well versed in how to best deal with an IRS audit.
Audit Representation
As a result of the decades of prior government experience members of our firm possess, including employment in the IRS Audit Division, as well as IRS Counsel’s Office, Andreozzi Bluestein LLP is extremely well versed in how to best deal with an IRS audit.
As a result of the decades of prior government experience members of our firm possess, including employment in the IRS Audit Division, as well as IRS Counsel’s Office, we are extremely well versed in how to best deal with an IRS audit. This significant experience greatly benefits our clients and enables us to obtain the best results possible. Clients know that their representation will be handled by experienced tax attorneys. Although Enrolled Agents and CPAs can, and often do, represent clients in the audit process, they cannot provide the protection that is given to our clients as a result of attorney/client privilege. Although tax professionals do have a level of protection in relation to privileged communication in a civil context, if the IRS determines that the case merits a criminal referral, the privilege is no longer available. This is when the privilege is most important. However, protected communication under the attorney/client privilege does not evaporate in the event of a criminal referral. This may be critical in protecting a client’s interests.
Our 25 years of experience includes the representation of individuals and businesses at all levels of a tax controversy in matters involving:
Income Tax Audits and Investigations
Innocent Spouse Litigation
Worker Classification Issues
Sales Tax Audits
Employment Tax Audits and Corporate Officer Liability and Trust Fund Recovery Penalty Cases
With our many years of experience, we will utilize every legal method available to protect our clients through the audit process and to obtain the best result. Additionally, in the event that the government’s proposal to resolve the audit is not as favorable as it should be, we have the experience and ability to take the case to the next level. Our firm has great success through the appeals process and the vast majority of our cases that are not resolved at audit are in fact settled favorably at the appeals level.
In the event it becomes necessary to go beyond the IRS appeals level, members of our firm have both government litigation experience as well as experience representing clients in the private sector before the United States Tax Court and the U.S. District Court. Although many cases are resolved prior to litigation, unlike CPAs and Enrolled Agents, we are fully prepared to litigate tax disputes on behalf of our clients.
If you are a business operating in New York State your chance of being selected for a sales tax audit has significantly increased in the past few years. Andreozzi Bluestein LLP represents individuals and businesses who are facing an audit of their income, sales or employment tax returns by the IRS or New York State taxing authorities. If your tax return(s) is selected for examination, you need experienced and knowledgeable legal counsel to make sure that your interests are protected throughout the audit process.
It is extremely important that a client is properly represented when confronted with an audit and we ensure that all the legal strategies and protections are made available to reach the most successful conclusion possible.
Latest News
Client Privilege – When you have it & when you don’t may surprise you.
By: Gary P. Bluestein Many accountants incorrectly assume that their communications with their tax clients are always privileged and confidential. Unfortunately, sometimes tax cases can cross over into potential criminal exposure ...
Read moreUnderstanding the IRS Collection Process (Part 4)
By: Margaret Fichtner This is the last entry in our 4-part series of understanding the lifecycle of a tax controversy. In Parts 1, 2 & 3 we discussed an overview of a controversy, understanding the audit process, and also the ...
Read moreIntroduction to IRS Appeals and the U.S. Tax Court (Part 3)
By: Michael J. Tedesco, Esq. Introduction to IRS Appeals IRS Appeals is a separate branch of the IRS, whose purpose is to resolve tax controversies between the IRS and taxpayers through an informal, administrative process, fairly ...
Read moreUnderstanding Audit, Issues and Strategies (Part 2)
By: Heather L. Marello, Esq. Types of Audits Pursuant to the IRS Data Book, during calendar year 2016, the IRS audited almost 1.1 million tax returns, or 0.5% of all returns filed. A representative never can (or should) predict ...
Read moreThe Lifecycle of a Tax Controversy (Part 1)
By: Michael J. Tedesco, Esq. We find that accountants and taxpayers are often unfamiliar with certain aspects of the typical tax controversy (i.e. how a tax matter moves through assessment, Tax Court/Appeals and Collections). We ...
Read moreWHY YOU SHOULD ALWAYS PAY YOUR PAYROLL TAXES: A PRIMER ON TRUST FUND RECOVERY PENALTIES (PART 1)
By: Kevin Murphy, Esq. PART ONE When we discuss potential liability for the Trust Fund Recovery Penalty (TFRP)- I.R.C. § 6672, we often find the need to explain how payroll taxes work. Many clients, some lawyers and ...
Read moreAndreozzi Bluestein Litigators Achieve Precedential Tax Court Victory for United States Virgin Islands Taxpayers
In a court-reviewed opinion published on January 29, 2018, the U.S. Tax Court in Coffey, et. al. v. Commissioner, 150 T.C. No. 4, found in favor of the taxpayers and dismissed the Internal Revenue Service’s Statutory Notices of ...
Read moreFBAR Penalties – The Government’s Coin-Flip Burden of Proof on Willfulness
By: Heather L. Marello, Esq. The Bank Secrecy Act of 1970, Pub. L. 91-507, 84 Stat 114 (Oct. 26, 1970), addressed the government’s desire to monitor the use of foreign bank accounts for illegal activities by authorizing the ...
Read moreWhat Tax Reform Could Mean For Your Clients
By: Michael J. Tedesco, Esq. On December 22nd, 2017 with one stroke of a pen, president Trump signed into law the most sweeping tax law changes in a generation. For the first time in over 30 years tax professionals will confront ...
Read moreAndreozzi Bluestein Attorneys Speak on Federal and State Compliance Issues
Buffalo Law Journal’s Michael Petro interviewed Andreozzi Bluestein’s Senior Associate Michael Tedesco and Associate Heather Schmidt on federal and state compliance issues for his Tax Law Special Report. Petro’s federal ...
Read moreWe are a law firm built on Experience, Vision & Trust
Whether you need tax counsel for litigation, representation before the IRS, an advocate in tax controversies, or thorough tax analysis and objective consulting, our attorneys have the experience and obtain lasting solutions.