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Tax Appeals

In California, as in many other jurisdictions, federal, state and local authorities have increased their tax collection efforts. This means more audits and more enforcement activities. Of course, any encounter with taxing agencies can result in an outcome that is devastating to your business, investment, or other financial activities. If you have received an outcome from the Internal Revenue Service (IRS) or state or local taxing authority you disagree with, you have a right to appeal that decision with the assistance of a Los Angeles tax appeals lawyer. Through the appeals process, you may be able to reduce your obligation substantially, or even eliminate it entirely. The tax specialists at the Ben-Cohen Law Firm have the knowledge, experience, and determination to help you reach the resolution you desire.

A complex process that requires skilled representation

If you are audited by the IRS and receive an unacceptable result, your next step may be to file a protest with a local IRS Appeals office. The Appeals division of the IRS is designed to provide you with an independent impartial review of your case after an audit is completed. The stated mission of the Appeals division is to resolve tax controversies, without litigation, on a basis which is fair and impartial to both the Government and the taxpayer in a manner which will enhance voluntary compliance and public confidence.

After a protest is timely filed, the Appeals officer that receives your case will set your matter for a conference, at which time the agency will explore the prospects of a settlement. The Appeals officer acts as both the fact finder and arbitrator. It is the function of the Appeals officer to close as large a percentage of his cases as possible on an “agreed” basis. Unlike Revenue Agents and other IRS personnel, an Appeals officer can take into consideration the so-called “hazards of litigation.” Hazards of litigation can be defined as the IRS determination of the probability that the IRS position might not be upheld by a court. Often it is the consideration of the “hazards of litigation” which will result in a favorable settlement for taxpayers.

If the Appeals conference does not resolve your case, the next step is the federal courts. You may even choose to bypass the Appeals process and proceed directly to court. The tax appeals attorneys at our Los Angeles firm can advise you on whether this may be appropriate. However, the Appeals process offers a viable avenue for resolution in many cases. It offers taxpayers the possibility of settling without the expense of litigation, while leaving the door open if the Appeals process concludes unsuccessfully. It also allows the taxpayer additional time before an obligation to pay any taxes related to the dispute, and creates the possibility of recovering attorneys’ fees if the court determines that the IRS action lacked sufficient legal justification.

Nonetheless, the Appeals process also carries risks. If the Appeals officer who reviews your case determines that the original auditor missed certain tax obligations, you may end up owing more, not less, as a result of the Appeals process. The help of an experienced and specialized tax attorney can be critical in helping you avoid an adverse IRS Appeals outcome.

Not just for federal matters

In addition to representing clients in appeals involving federal matters, our tax appeals lawyers also assist Los Angeles clients and others with state tax disputes. Similar to the federal process, you have the right to appeal a California Franchise Tax Board assessment, and the process starts with filing a written protest. The next appellate steps are to proceed to the State Board of Equalization, and then to the court system. At our Firm, we frequently represent clients before each of these agencies.

Tax appeals can be complex and tricky matters, with procedural pitfalls that may be traps for the unwary. Our firm has a long track record of handling these matters, from the protest stage to the highest judicial appeals. We provide our clients with comprehensive advice regarding how to proceed through this complicated process, and stand by them through every step. If you have concerns about the potential appeal of a tax dispute, contact the tax attorneys at the Ben-Cohen Law Firm. Our Los Angeles tax appeals attorneys have the tools and the determination to help you reach the best possible outcome.

Client Reviews
I approached Mr. Ben-Cohen regarding a pending case with the State of California and my small business. During a time that was quite stressful, I found Mr. Ben-Cohen to be the perfect person to represent me and my company. He communicated with me in clear terms so that I understood everything that was taking place in a timely manner. He treated my situation with the type of candor you only find in a consummate professional and successfully negotiated a deal with the State of California that far exceeded my expectations. I found him to be kind, efficient, sensitive and nothing short of brilliant. I consider myself fortunate to have met him and highly recommend his services. I will not hesitate to use his firm in the future should a need arise.
★★★★★
I am an international tax advisor and have worked with Pedram on more than a dozen difficult and challenging cases. Pedram's clients and fellow advisors highly respect him because he has an uncanny ability to quickly identify and work diligently to resolve his clients' issues. Pedram is pragmatic in his approach. He is transparent with his clients and dedicated to getting to a fair and reasonable outcome. I have attended an IRS Appeals conference with Pedram and would want no other attorney on my side. Pedram is extremely passionate in his work and representing his clients. He is also enjoyable to work with and develops very good relationships with his clients and fellow advisors. I highly recommend Pedram for any tax controversy work. Avvo, Curt
★★★★★
Top Drawer Tax Fraud Lawyer. Pedram got me out a CI jam I thought I would not resolve. He is also fair and reasonable with his billing. I interviewed 4 top Tax Fraud Lawyers in LA and went with Pedram...Glad I did! Google, Michael Jeppson
★★★★★
Pedram Ben-Cohen at Ben-Cohen Law Firm, PLC is one of the most incredible, creative, and caring attorneys I have ever dealt with. He gave us hope but also gave us the reality and worst case scenario. He fought for us tooth and nail. The attention and time Pedram put into the case was like no other. He charged us more than fair and was very reasonable in every aspect. He is not the kind of attorney that charges for every minute. I liked him very much not only as an attorney but as a person because he is very honest, is true to his integrity, and is dedicated to his clients. He loves what he does and has the passion to protect and defend his clients, which totally shows in his work and our outcome. We originally hired another attorney from a famous firm who basically did not give us much hope on our case . That is when we came to Pedram who won our case in a short amount of time and got us the outcome we were looking for. Because of Pedram and his creativeness, willingness, and dedication, he got us our favorable outcome. He is our go to attorney for sure, without a doubt. Avvo, Anonymous
★★★★★
A few years ago I had a major tax problem and I was looking for the right professional tax lawyer. I interviewed at least five experts and all of them were very professional. I am very picky. When I met Mr. Pedram Ben-Cohen, it took me no more than five minutes to decide that he was the one, and I was absolutely right with my intuition. He is very professional, knowledgeable, smart, and knows his job perfectly. In addition to all of his professional skills, as a person he is very friendly, pleasant, ready to help, and took care of me like I was his own family. I referred and recommended him to friends and family with tax problems and will continue to do so warmly to anyone. I know that he is able and will do his job the best way for his clients. He is my personal tax lawyer and expert and will remain so. Google, Shlomo Kattan
★★★★★
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