Tax Litigation
The IRS has many incentives to settle a case at the appeals level, and not pursue a matter in the court system. The main reason for is that if the IRS loses a case in court, it could possibly create legal precedent that binds them in a particular issue in for all other cases on the same issue.
However, if the IRS refuses to settle your case in appeals, we will aggressively pursue the issue in court. We are licensed to practice in front of the United States Tax Court, The United States District Courts for the Southern, Central and Eastern and Northern District of California, and the United States Ninth Circuit Court of Appeals.
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(714) 321-3369