Federal Tax Controversies

At Neschis & Tolitano, LLC, (Neschis & Tolitano), we have a diversified and comprehensive federal tax controversy practice that covers a broad spectrum of tax issues. We regularly assist taxpayers at all levels of a dispute with the IRS from audit through litigation in the United States Tax Court or United States District Court.

Tax Audits, Appeals And Litigation

Our representation at the audit level involves developing strategies for all issues involved in the audit and responding to all of the IRS's information and document requests, and to all of the IRS's proposed tax adjustments to a taxpayer's tax return. If the taxpayer and the IRS do not agree on one or more items in the audit, the taxpayer may file an appeal with the IRS Office of Appeals. Our attorneys are skilled negotiators and have significant experience representing individuals and businesses at the appeals stage. We also have significant experience with the numerous alternative dispute resolution options available to taxpayers during the audit and appeals processes. Additionally, we have also represented numerous taxpayers dispute a tax assessment through litigation in United States Tax Court, Federal District Courts and the U.S. Court of Federal Claims. A litigation case can typically be initiated by a taxpayer who does not agree with the audit results or appeals decision and after receiving a Notice of Deficiency or filing a claim for refund with the IRS.

Our lawyers also have extensive experience assisting taxpayers become compliant with U.S. tax laws related to undisclosed foreign accounts and assets. These cases typically involve taxpayers who have failed to report their foreign income on their originally filed income tax returns and have failed to file an annual Report of Foreign Bank and Financial Accounts (FBAR) form. We have assisted numerous taxpayers enter and participate in the Offshore Voluntary Disclosure Program (OVDP) in an effort to minimize penalties that may otherwise apply due to their failure to report foreign income and file the required annual FBAR forms and have also assisted in tax audits and criminal investigations related to these accounts and assets.

Tax Collection Matters

We regularly represent taxpayers with outstanding tax liabilities before the IRS's collection division. Our tax collection cases involve a broad range of tax collection assistance to include the following:

  • Installment agreements
  • Offers of compromise
  • Abatement of penalties
  • Release, withdrawal, discharge and subordination of federal tax liens
  • Release and withdrawals of levies, including wage garnishments and bank levies
  • Innocent spouse relief
  • Currently uncollectible status
  • Collection due process notices
  • Trust fund liability or civil penalty assessments

Contact Neschis & Tolitano

Call us at 847-635-7877 or by email to schedule a consultation. Located near O'Hare Airport, we serve clients throughout Des Plaines, DuPage, Will, Lake and McHenry counties, Illinois.