Tax controversy, from notice to verdict.
More than ten years representing individuals and small-to-mid-sized businesses before the IRS and state taxing authorities. Michael Goldberg is a tax attorney and CPA with an LL.M. in taxation from Georgetown Law — and is frequently asked to lecture on tax controversy topics, including to IRS Revenue Officers.
Representative matters
Offer in Compromise
Settle IRS tax debt for less than you owe with a strategic, legally sound resolution.
Tax Collection & Relief
Resolving IRS debt, stopping collections, and protecting your financial future.
Tax Litigation
Experienced representation in IRS disputes, audits, and Tax Court cases.
Trust Fund Recovery Penalty
Aggressive defense for business owners and officers facing personal payroll tax liability.
Employee Retention Credit (ERC)
Defense against ERC audits, repayment demands, and IRS enforcement actions.
Residency Audit Defense
Strategic representation for taxpayers facing domicile and residency disputes.
Innocent Spouse Relief
Tax debt protection for divorce and spousal tax disputes.
Cryptocurrency Tax
IRS defense for crypto audits, unreported digital asset income, offshore wallets, and enforcement actions.
International Tax & FBAR
Strategic legal defense for offshore reporting, voluntary disclosure, and international tax enforcement.
Criminal Tax Issues
Strategic defense for taxpayers facing IRS criminal investigations and tax fraud exposure.
Discharge of Tax Liens
Remove IRS liens from property to enable sale, refinancing, and credit recovery.
Mergers & Acquisitions
Strategic tax planning and risk management for business acquisitions, sales, and restructurings.
Strategic Tax Planning
Industry-specific tax planning designed to reduce risk, improve compliance, and maximize long-term financial efficiency.
Bring it in. Most IRS letters have hard deadlines — sometimes 30 days, sometimes 90. The cost of waiting is almost always higher than the cost of an early call.
- U.S. Tax CourtFederal
- IRS Appeals & ExaminationFederal
- NY Division of Tax AppealsNew York
- Maryland Tax CourtMaryland
- D.C. Office of Tax & RevenueD.C.
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Confidential. No obligation. We respond within one business day.