Law Offices of Alyssa Maloof Whatley LLC

Our firm specializes in all phases of federal and state tax controversy work. Typically, a taxpayer will file a return and years later receive a notice that their return is under audit. While this may be an extremely stressful event for the taxpayer, the IRS and state tax authorities give taxpayers many opportunities to dispute additional assessments.

The IRS will send a 30-Day letter with the proposed deficiency, which gives the taxpayer an opportunity to protest the deficiency. If the taxpayer timely files a protest, the case is sent to appeals to resolve the dispute. If the taxpayer fails to protest the proposed deficiency, the IRS will send a Notice of Deficiency 90-Day Letter, which allows the taxpayer to file a petition with the United States Tax Court.

If the taxpayer misses this deadline, the tax is assessed regardless of validity. If a Tax Court Petition is filed, the case is sent to appeals to attempt to resolve the dispute. If no agreement can been reached, the case moves forward to prepare for trial. Most of the time, the case is resolved with IRS Chief Counsel’s Office prior to litigation and a decision document is signed which determines the deficiency or over payment.

It is very important to hire a licensed experienced tax attorney as soon as possible in an audit or correspondence examination due to the number of deadlines and opportunities to settle disputes early, which can reduce stress and cost on the taxpayer.

Our Atlanta Tax Attorneys are able to diligently and quickly research the issues, help the tax payer gather necessary documentation and evidence to defend or support their claim, and most of the time, greatly reduce the tax and penalty assessment.

Even if a taxpayer has missed their opportunity to dispute the tax through the normal channels discussed above, the taxpayer still has options to dispute and correct the tax. These options include Audit Reconsideration and Offer in Compromise Doubt as to Liability.