Tax Litigation
Experienced representation in IRS disputes, audits, and Tax Court cases.
Tax litigation arises when a disagreement between a taxpayer and the IRS cannot be resolved through normal administrative avenues. Goldberg Tax Law provides experienced representation in federal and state Tax Court helping clients protect their rights, reduce tax liabilities, and resolve disputes efficiently.
What is tax litigation?
Tax litigation refers to the legal process of disputing IRS or state tax agency actions when negotiation or administrative appeals fail. In these cases, the dispute moves into a formal court setting where evidence, legal arguments, and expert testimony determine the outcome. Common issues that lead to tax litigation include:
- Disputes over the amount of tax owed
- IRS assessments that the taxpayer believes are incorrect
- Penalty disputes
- Refund claims
- Issues involving deductions, credits, valuation, or income reporting
Types of tax litigation cases we handle
Our approach to tax litigation
We take a strategic and evidence-driven approach to every case:
- Careful review of IRS records and case files
- Identification of legal weaknesses in the IRS’s arguments
- Expert analysis of tax law and precedents
- Strong negotiation supported by litigation readiness
- Clear communication at every stage of the case
Why work with Goldberg Tax Law?
- Specialized tax litigation experience in federal and state courts
- Efficient dispute resolution to reduce stress and uncertainty
- Deep expertise in complex tax issues and forensic tax analysis
- Transparent communication and proactive case updates
- A client-first philosophy focused on achieving the best possible outcome
Understanding the courts
U.S. Tax Court is the most common venue for tax disputes—you do not need to pay the tax before filing. U.S. District Court is used primarily for refund litigation where the tax must be paid first. The Court of Federal Claims accepts refund cases against the federal government and is often beneficial for complex or technical disputes involving federal law.
Frequently asked questions
A Notice of Deficiency is the IRS’s formal determination that you owe additional tax. You have 90 days (150 if abroad) to file a Tax Court petition. Missing the deadline allows the IRS to assess and collect the tax.
No. In most Tax Court cases, you file before paying, which is why Tax Court is the most common venue for disputes.
Anywhere from several months to over a year, depending on complexity, discovery, and court scheduling.
Yes. Most cases settle during litigation once IRS Counsel reviews the records and legal issues.
You can appeal the audit results and, if unresolved, file in Tax Court after receiving the Notice of Deficiency.
Refund litigation occurs when the IRS denies your claim for a refund. You must pay the tax first before filing in District Court or the Court of Federal Claims.
Not always. Many cases settle without a trial. If trial is required, your appearance may be needed, and we will fully prepare you.
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