Federal and state tax problems are among the thorniest and most difficult legal matters to resolve successfully. They generally involve complicated legal, accounting and business issues, the potential for collection of unpaid taxes and interest and the possibility of civil and criminal penalties. More often than not, the cases cover multiple years and involve the tax returns of both individuals and their businesses. In the case of married taxpayers, one of the parties may seek innocent spouse relief.
Members of the Capes, Sokol, Goodman & Sarachan, P.C. Civil and Criminal Tax Controversy practice group focus on getting control of their clients’ tax problems, managing the risks, minimizing the personal and financial impact and achieving the best possible results. We offer an honest and frank assessment of the situation faced by individuals and businesses under investigation or embroiled in tax law controversies, based upon expert knowledge and a wealth of experience in this specific area of law.
The Capes Sokol Civil and Criminal Tax Controversy group includes attorneys with more than 80 years of combined experience in providing local and national representation in tax cases, as well as a retired Special Agent who worked for the IRS for 28 years prior to joining the firm. While it is often preferable to reach an agreement out of court, our team has extensive experience litigating tax cases in all forums available to our clients to resolve their disputes.
Our experience spans all areas of civil and criminal tax controversy, including the following:
- Investigations for tax evasion and other tax and financial crimes, including money laundering, failure to file tax returns and tax return preparer fraud
- Investigations involving foreign bank accounts
- Investigations related to failure to file FBARs
- Defense before the IRS and DOJ Tax Division
- Administrative conferences with the IRS, as well as conferences with the Tax Division of the Department of Justice
- Criminal tax litigation in federal district court
- Representation of witnesses, subjects and/or targets in responding to IRS Summonses and/or Grand Jury Subpoenas
- Voluntary disclosures
- IRS income, estate and gift and excise tax audits
- Appeals of proposed federal tax deficiencies to the IRS Office of Appeals
- Mediation with the IRS Office of Appeals
- Assistance in responding to an IRS Notice of Deficiency
- Litigation against the IRS before the United States Tax Court
- Claims for refund and tax refund litigation in Federal District Courts and the Federal Court of Claims
- Requests for innocent spouse relief, appeals and litigation
- Advice regarding the statute of limitations for assessment and collection of additional tax by the IRS
- Trust fund recovery penalty investigations and appeals
- Collection Due Process appeals
- Representation of tax practitioners, including C.P.A.’s and lawyers in preparer/promoter penalty investigations and litigation before the IRS and Tax Division of the U.S. Department of Justice
- Representation of tax practitioners in injunctive actions brought by the Tax Division of the U.S. Department of Justice
- Representation of tax practitioners before the IRS Office of Professional Responsibility in matters involving Circular 230
- Missouri state income and sales and use tax audits and examinations
- Appeals to the Missouri Administrative Hearing Commission
Capes Sokol professionals providing Civil and Criminal Tax Controversy services are:
Attorneys
Laura E. Krebs Al-Shathir
Sanford J. Boxerman
David V. Capes
Sara G. Neill, Practice Group Chair
Michelle Feit Schwerin
Paralegals
Megan L. Haupt
Other Professionals
Jeanne M. Schaller, Forensic Accountant