Tax Litigation

A competent tax attorney can help you navigate the legal landscapes of the Internal Revenue Service and California tax authorities. By utilizing an attorney early in the process, you can possibly minimize the long-term cost and frustration associated with trying to litigate a tax matter alone.

Tax Collection

The Internal Revenue Service and California tax authorities have a complex system by which they attempt to collect money from you.

We offer an analysis of your tax situation, to determine where you are in the collection process. We can determine if you owe back taxes or need to file prior tax returns. We will negotiate with the tax authorities to place you in a situation you are comfortable with, whether that is placing you on an installment agreement (payment plan) or doing an Offer in Compromise (tax settlement).

Our aim is to ensure that once you step into our office and we get you back on track, you will not have to return. That is, we try to place you in a situation you are comfortable with and can maintain. It is critical to understand that whatever arrangement you reach to stop the collection process, it can begin again if certain requirements are not met, such as timely filing tax returns, and not incurring new tax liabilities.

Sparacino Law can also represent you in the event your collection matter needs to be litigated in Appeals, the United States Tax Court, United States District Court or Court of Federal Claims.

Tax Return Audit

An audit is viewed by most taxpayers as one of the most dreadful things to have to go through. It is critical to have competent representation to guide you through this process. Sparacino Law with work with the taxing authority in a cordial yet effective manner. We will do a detailed financial analysis of your records as they relate to your tax return. We will use our legal ability to argue your case and our sound judgment to give you the best possible result.

Our aim is to guide you through the audit as quickly and efficiently as possible, with minimal effect on your personal life or business operation. In the event of a possible criminal tax risk, we will use our ability to try to minimize that risk with evidence. An audit is certainly a process that should be not defended alone. You need competent advice.

In the event the audit results need to be appealed, or litigated we can ensure that your Notice of Deficiency is properly handled. We are not reluctant to pursue a case in Tax Court.

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Representative Matters

• Client was a victim of a Ponzi Scheme and lost thousands of dollars in a failed investment. Client took an expense for the amount invested as a debt that could not be collected. The IRS disallowed the expense, and alleged the client owed tax to the extent of $100,000. After bringing the matter to Tax Court, the IRS reversed its position and agreed that the client owed no additional tax.

• Client took a distribution from a retirement account and paid the required tax. The IRS claimed the client owed an additional $16,000 in tax. After presenting evidence and argument, the IRS reversed its position and agreed that the client owed no additional tax.

• Client was subject of an audit. Significant financial analysis and explanation resulted in a finding of no additional tax owed. Only one of three possible years were examined.