What is a tax controversy attorney?

A tax controversy attorney represents taxpayers in disputes with federal, state, and local tax authorities. This includes IRS audits, administrative appeals, collection defense, and litigation in the U.S. Tax Court, Court of Federal Claims, and U.S. District Courts.

Do you handle IRS audits and appeals?

Yes. We represent taxpayers throughout the audit process, before the IRS Office of Appeals, and in litigation if a matter cannot be resolved administratively. We also defend taxpayers in IRS collection matters, including liens, levies, and installment agreements.

Can you help with Florida sales tax and use tax disputes?

Yes. We represent businesses and individuals in Florida Department of Revenue disputes involving sales tax, use tax, intangibles tax, and corporate income tax, including audits, protests, and collection matters.

What is the IRS Streamlined Filing Compliance Procedure?

The Streamlined Filing Compliance Procedures allow eligible U.S. taxpayers whose failure to report foreign financial assets was non-willful to come into compliance with reduced penalties. We counsel taxpayers on eligibility, prepare required filings, and advise on Voluntary Disclosure and FBAR matters.

Where is your tax controversy law firm located?

Gutter Chaves Josepher Rubin Forman Fleisher Miller PA is located at 2101 NW Corporate Blvd., Suite 107, Boca Raton, FL 33431-7343. You can reach us at 561.998.7847.

Tax Controversies & Collections | Boca Raton

Tax Controversies & Collections

Federal Tax Controversies & IRS Disputes

Our Boca Raton tax controversy attorneys represent taxpayers in federal income tax, transfer tax, excise tax, and other IRS disputes and collection matters. Representative engagements include:

Assistance with IRS audits or direct representation in audit proceedings
Representation before the IRS Office of Appeals
Representation before the U.S. Tax Court, U.S. Court of Federal Claims, and U.S. District Courts at pretrial and trial stages
Defense of IRS tax collection matters, including liens, levies, installment agreements, and offers in compromise

Florida State and Local Tax Disputes

We represent taxpayers in sales tax, use tax, intangibles tax, corporate income tax, and other Florida state and local tax disputes and collection matters, including audits and protests before the Florida Department of Revenue.

Offshore Tax Compliance & Voluntary Disclosure

We counsel taxpayers on offshore compliance issues, including the IRS Voluntary Disclosure Practice, Streamlined Filing Compliance Procedures, FBAR and FATCA reporting, and other international tax compliance concerns.

Contact Our Boca Raton Tax Controversy Attorneys

Gutter Chaves Josepher Rubin Forman Fleisher Miller PA

Boca Corporate Center
2101 NW Corporate Blvd., Suite 107
Boca Raton, FL 33431-7343

Directions
P. 561.998.7847 | F. 561.998.2642

Recent News

15 May 2023

Jenna Rubin presents at ABA National Symposium

On May 12, 2023, Jenna Rubin presented at the 35th Annual Real Property Trust and Estate Law Section of the American Bar Association’s National CLE Conference in Washington DC. She took part in a panel discussion on “Black Tie Optional: The Eroding Formalities to Creating a Valid Will.”

24 Feb 2022

Article by Charles and Jenna Rubin featured on cover of Florida Bar Journal

An article written by Charles Rubin and Jenna Rubin is featured on the cover of this month’s Florida Bar Journal and can be found here.

27 Dec 2021

Jenna Rubin appointed to ACTEC Fiduciary Litigation Committee

Gutter Chaves is pleased to announce that Jenna G. Rubin has been appointed to the Fiduciary Litigation Committee of the American College of Trust and Estate Counsel (ACTEC) for the 2022-2023 year.

14 Dec 2021

FBAR Case Reversed – Nonwillful Filing Penalties Based on Number of Accounts Not Reported

Back in 2000, I wrote here about a case where a taxpayer did not report multiple foreign accounts on an FBAR. The question for the court was whether the $10,000 penalty for a nonwillful failure to file meant $10,000 per return not filed, or $10,000 per account not reported on the return. For . . .

22 Nov 2021

Of Spousal Gifts and the Substance Over Form Doctrine

U.S. spouses each have a unified credit that allows for substantial gifting to third parties without requiring the payment of gift tax. What happens if one spouse has assets to be gifted away, but that spouse does not have sufficient remaining unified credit exemption to cover the gift and wants to use the exemption of the other spouse?

At times, the spouses can agree to split the gift for gift tax purposes, which treats 1/2 the gift as coming from each spouse. This allows the unified credit of the spouse not making the gift to be used to avoid gift tax on the 1/2 that such spouse is treated as making. However, it can be an imperfect solution if the spouse with the assets does not have enough unified credit to offset his or her 1/2 of the gift.

Oftentimes, the parties may contemplate having the party with the assets transfer them by gift to the other spouse (a tax-free gift under the gift tax marital deduction), and then the receiving spouse makes a gift to the third party applying his or her own unified credit. The question in these circumstances is whether the IRS will respect the transaction and allow the receiving spouse’s unified credit to be applied to the gift to the third party, or whether it would seek to apply the “substance over form” doctrine to treat the gift as coming from the spouse who transferred the assets to the other spouse and does not have enough unified credit to fully cover the gift.

This is not a black and white issue. On one end of the spectrum. . .

Tax Controversies & Collections

tax, estate planning, probate, trust & guardianship law and litigation, and related commercial matters