AREAS OF PRACTICE

Fiscal Defenses in the Administrative Sphere

The IRS has increasing access to taxpayers’ data. Part of this information is provided by the taxpayer on IRS forms sent in regularly (DIPJ, DCTF, DIRPF, DIRF, etc.), part by statements provided by third parties such as financial institutions, registries, property registry, credit card management companies, etc. This set of data meets the IRS's needs and allows for more objective and effective tax audits.

Once the verification procedure is completed, taxpayers are ordered, through IRS notices and bills, to pay any tax difference that the IRS understands is due. Once the taxpayer is aware of the tax liability, the limited period allowed for a tax defense begins.

The firm has wide work experience in the administrative domain, and it allies legal and accounting expertise in their tax defense strategies. Such events are accompanied by professionals who have worked as judges and presidents of governing bodies of trial and now devote their expertise to defending the interests of our clients.

The rules governing the tax administrative process differ from those in judicial proceedings and are specific to each federal entity (Municipal, State and Federal). Only a lawyer with the education and experience focused on tax administrative processes will use all resources and expedients, often referred to only in the internal regulations of each agency, in order to achieve the client's interest and reverse the charges resulting from a tax audit.