Civil Tax Controversies & Trials

With extensive experience in civil tax controversies and trials, Norman Spencer & Associates has a well established track record in representing clients from all over the country before the Internal Revenue Service, and also before New York State and City tax authorities.

Joseph Potashnick & Associates leverages their many years experience, their considerable talent and expansive resources in dealing with both the practises and the personnel of revenue agencies.

Our firm has regularly represented clients wishing to limit their civil liability or clients who have historically failed to file tax returns.

Through the successful negotiation of numerous voluntary disclosures with the Internal Revenue Service we have assisted our clients in avoiding not only criminal prosecution but also in limiting civil penalties, particularly in the case of clients who have extensive foreign bank accounts—including but not limited to those clients with foreign trusts, foundations, corporations, and nominees, or on behalf of clients who failed to report sizable income earned from United States businesses and investments.

Further, our firm has achieved positive resolution, in the form of considerable sums of money, in potential liability arising from the alleged abuse of tax shelter investments.

In tax matters, our firm seeks an expedient and successful resolution on behalf of our clients. We remain committed to our clients needs and to resolving tax matters to their advantage, whether that be through resolution of tax controversies prior to litigation or taking the matter to trial. We have the experience to maintain the tactical advantage for our clients in:

• Tax authority negotiation
• Tax Litigation (all phases)
• Response to summons and subpoenas
• Preparation of administrative protests and petitions, discovery, depositions, dispositive motions, trials, and appeals.

Our experience extends also to clients dealing with demands for documents or testimony in connection with the examination of other tax payers in the following areas:

• Employment Tax Defense
• Defense of Offshore Financial Institutions and Account-Holders
• IRS Audit Defense
• Defense of IRS Promoter Investigations
• Defense of Captive Insurance Programs
• Tax-Related Internal Investigations
• Defense of Accountants and Tax Return Preparers
• Defense of Parallel IRS Civil and Criminal Investigations
• Tax Whistleblower Representation
• Passport revocation for seriously delinquent tax debt

In matters related to federal tax our clients, drawn from across the United states, include not only individuals but corporations (both public and closely-held) and partnerships.

At Norman Spencer & Associates we regularly represent our clients before the Examination Division, Appeals Office, and the Internal Revenue Service Collection Division.

Our team of skilled and knowledgeable attorneys frequently try cases in the United States Tax Court, the United States District Courts, and the United States Court of Federal Claims.
They have obtained, on behalf of their clients, numerous abatements of penalties, acceptances of offers in compromise, and innocent spouse relief.

We handle both estate tax and gift tax matters.

Alongside our considerable experience related to Federal Tax matters, our team is au fait with and can assist both corporate and individuals, in all aspects of state tax, including:

• Corporate Franchise
• Sales
• Payroll
• Personal Income Taxes

Notably, our familiarity with New York State and City tax matters enables us to litigate, and frequently obtain successful outcomes, in cases of authorities challenging taxpayers who seek a residential change in mitigation of the extremely high tax rate imposed on taxpayers by New York State and City.