Tax Controversies

Respond to production requests


The IRS may request any taxpayers to produce documents and books related to a specific tax period or filing. It is very important to respond to such requests. However, a taxpayer would benefit tremendously from a Tax attorney's representation.

I will review requests and raise proper objections or facilitate further negotiations regarding the production of documents. I will assist with response preparation and organization to ensure that only requested information, within the scope of the request, is produced. Finally, I will ensure that clients properly address missing evidence to avoid possible allegations of concealment or fraud.

  • ​​Representation in audits, investigations,          and tax trials
  • Bankruptcy strategies for tax relief

Represent you in audits and tax trials

Tax audits are very complicated proceedings. I will represent my clients and ensure that all of their procedural and substantive rights are protected before, during and after the IRS has conducted the audit. I will perform a pre-audit document review and give you a fair assessment of possible issues that could be relevant to you situation.

Some tax relief is available with the help of the US Bankruptcy Code. Bankruptcy is not an ideal way of dealing with your current tax problems. However, under some circumstances, and especially in back-taxes, liens and foreclosure situations, bankruptcy code will allow an organized approach in settling disputes with the IRS. I will discuss all available options and together we will find a suitable solution for your particular case.

  • Innocent Spouse Relief​
  • Negotiations and settlements of tax disputes Filing missing tax documents

Innocent Spouse Relief    

Married taxpayers who choose to file a joint tax return are each legally responsible for all taxes, interest, and penalties due, even if only one of the spouses was the source of income and mischief or manipulations. However, the IRS recognized an important exception, known as the Innocent Spouse Relief that allows an "innocent" spouse to get a relief from all or substantial portion of the assessed taxes, interest and penalties.

Those requesting innocent spouse relief from the IRS must meet all of the following conditions:

  • The moving spouse was not directly “at fault” for the misreporting and the other spouse was the sole attributor of the tax misconduct.
  • At the time of tax return submission and signing the "innocent" spouse had neither direct, nor constructive knowledge of the tax misconduct.
  • As a matter of equity, it would be wrong to hold the innocent party liable, under the totality of the circumstances test.
  • The defense of innocent spouse relief was properly raised within 2 years from the date of the original assessment of the tax liability.
  • Offer in Compromise
  • Small business and Self-employed tax help

Tax issueswill not go away.  The IRS has resources to enforce tax laws to the full extend. You deserve to be represented by a knowledgeable and experienced

Tax Attorney with all your tax needs. 

Call now  (267) 443-7755 or (908)300-3406

  • Reasonable fees
  • State and Local (SALT) Tax Controversies

Most often, the largest portion of a delinquent tax bill is the penalties and interest. They add up quickly. Before any settlement or payment is made, let me review your assessment and determine whether the penalties and interest charges are justified. Some, if not all, charges could be reduced. Getting an advice from a Tax attorney makes a big difference. 


Don't Ignore the IRS  ~  They Won't Go Away!


I will negotiate with the IRS for the best possible scenario. Our financial planning will help your quick post-delinquency credit recovery. If you have received any certified correspondence from the IRS or have been served, do not wait. Contact me as soon as possible to secure a representation. Do not respond or contact the IRS without consulting your Tax attorney first. 

  • Respond to production requests

Tax problems could be very devastating. The IRS has enormous powers and can:

  • Garnish Your wages
  • Seize and sell your assets
  • Seize/levy your residence
  • Put Federal Tax lien on your property
  • Collect on your 401k and retirement accounts
  • Intercept your tax refunds


Tax problems will ruin your credit, employment opportunities and professional memberships and licenses.

Litvak Legal Group, PLLC.