A Tax Law Firm Serving Individuals and Businesses

More Art, Less Science – Managing a Tax Dispute

The Miles Consulting Group, helps companies doing business across state lines with  multistate tax needs. They often assist clients in audits and other disputes with state agencies.

I recently wrote a guest blog post for their website looking at disputes from the federal standpoint and things to consider before engaging in tax planning.

Here is an overview of the guest blog post.

On March 23, 2017, the IRS Large Business and International (LB&I) division announced the initial identification and selection of 13 “campaigns” to combat perceived tax compliance issues, with more campaigns to be identified and launched in coming months.

In its announcement the IRS has indicated that depending on the particular issue, the “treatment stream” (a great example of IRS-speak) may include starting an issue-focused examination or issuing a “soft letter” (where the IRS invites the taxpayer to either amend its tax return or respond to the IRS explaining why the taxpayer’s treatment of a particular issue was appropriate).

All of this begs the question — and this applies to a dispute with the IRS as well as any other taxing authority– of how should a taxpayer manage a dispute with the taxing authority.  Based on my 25+ years of practice as a tax attorney (and with the standard tax attorney caveat that of course these rules could change depending on the circumstances), here are my four rules for how to manage a dispute with a tax authority.

  1. The best defense is a good offense.
  2. Be proactive in dealing with the tax audit.
  3. Help the auditor be your advocate.
  4. Know when to fight; Know when to fold.

You can read the full post, with details on each of the 4 rules, here:


H.T. Astrov helps clients in the San Francisco East Bay and  nationally find peace of mind and practical solutions to their IRS tax problems.  H.T., an attorney and non-practicing CPA, has more than two decades of experience providing counsel on a wide range of U.S. and non-U.S. tax matters.  His background includes serving as an Attorney-Adviser for the IRS Office of Chief Counsel in Washington, D.C. and as Senior Tax Counsel for Chevron in San Ramon, California.  H.T. received his B.S.B.A. from Georgetown University, his J.D. from The Ohio State University Moritz College of Law, and his LL.M. (Taxation) from Georgetown University Law Center.

If you are facing a tax issue with the IRS  contact us today by calling (925) 828-2415 or email us.