San Francisco Tax Litigation

We Handle Your Disputes with the IRS & Help You Decide When To Challenge U.S. Tax Court Findings

At Moskowitz LLP, our highly experienced San Francisco tax attorneys are skilled in using Tax Court litigation as a powerful tool to defend your rights, minimize liabilities, and achieve favorable outcomes that can’t always be secured through negotiation with the IRS alone.

While many taxpayers fear the idea of going to court, the truth is that litigation can be a highly effective strategy when dealing with the IRS.

OUR SAN FRANCISCO OFFICE: Moskowitz LLP is located on Bush Street between Kearny St and Montgomery St at 333 Bush St Floor 21, San Francisco, CA 94104 in the Financial District (view on Google Maps), about a block away from St Mary’s Square.

Recent Review: $136,000 Saved!

“I have been with Steve’s firm over the last 3 years. It was all new to me being audited and threatened with letters by the IRS of audit. Then recalculating previous tax years and deciding I owe more with penalties and interest. And even having to prepare for tax court. The whole time I felt I was in good hands with this law firm. Each lawyer and their legal assistants that were handling my cases, treated me professionally, supportive and were always updating me with how it was progressing and if I had questions for them. One tax year, they even managed to get an IRS demand and threat of tax court thrown out for legal reasons the IRS would have never told me if I was on my own! I was looking at revised audits for 4 years and demanded estimated back payments and penalties well over $150,000! It’s been reduced to under $14,000 settled on… It was tough to have to still pay back taxes with business writeoffs not allowed after the fact, but there was a lot they fought the IRS over and had them back off and relent… I have had a most positive experience dealing with Steve and his staff. I trust them.“
Verified Google Review From Mel C.

Choose Moskowitz LLP as Your Tax Law Firm

The IRS has an army of attorneys and financial professionals who are ready to take you on. Moskowitz LLP is the ace up your sleeve. Our team includes highly experienced tax attorneys, CPAs, enrolled agents and accountants – all of whom know how to best represent you and your business in tax court.

Moskowitz LLP was founded by attorney Steve Moskowitz, who has over 40 years of experience in federal & state tax law. Mr. Moskowitz and our firm has handled countless matters involving the IRS, California Franchise Tax Board, international tax law and criminal tax law.

Moskowitz LLP has hand selected tax & financial professionals with diverse industry knowledge to better serve our clients who are facing legal challenges with the IRS. If it’s a problem for you today, chances are we’ve seen it before.

Cases We Handle

U.S. Tax Court Litigation:

• Removal of Business Expenses Litigation
• Passive Activities v. Active Participation Litigation
• Collection Cases Litigation (Improper Levies, Liens, and other collection activity)
• Real Estate Professional v. Passive Participation Litigation
• IRS Failure to Comply with Procedure (Failure to Provide Notice of Deficiency, Manager Penalty Approvals, and More)
• Solar Credit Litigation
• Depreciation Deduction Removal Litigation
• Tax Basis Calculation Litigation (Real Estate Basis, Employee Stock Options, Shareholder Basis, Investment Basis)

Federal District Court Litigation:

• Claim for Refund Litigation
• ERC Litigation

Franchise Tax Board, California EDD, and CA CDTFA Litigation:

• Office of Tax Appeals (FTB and CDTFA)
• California Unemployment Insurance Appeals Board Litigation (EDD)

Our team has extensive experience representing clients in Tax Court, where we rigorously challenge IRS determinations and fight to protect your rights, income, assets, and financial future.

The Tax Court was formed to allow people to present their case in a fair and impartial atmosphere. We will do everything possible for you, within the bounds of the law, to strive to obtain for you the best possible outcome, regardless of your facts and circumstances including all the work that is done before trial to obtain our goal in a settlement without going to trial; however, everything that we do is for preparing for trial if that is what is in your best interest.

Why Choose Tax Court?

• No Need to Pay First: One major advantage of filing a case in Tax Court is that you are not required to pay the disputed tax amount before the trial. This preserves your cash flow and allows you to fight the IRS without being forced to make payments you may not owe.
• Independent Review: U.S. Tax Court judges are experts in tax law and provide an impartial review of your case. This means that instead of negotiating with the IRS agents, who are advocates for the IRS, who originally audited your return, your case is decided by a neutral party well-versed in tax law complexities.
• Strategic Leverage: Filing a case in Tax Court can serve as powerful leverage in negotiations with the IRS. Knowing that you are willing to take your case to court can encourage tax authorities to offer more reasonable settlement terms or make concessions they might not otherwise consider.
• Legal Experience to Maximize Your Defense: Tax law is incredibly technical, and a strong legal strategy can make the difference between success and failure in court. At Moskowitz LLP, we build your case on the facts and the law and use our deep knowledge of both tax law and IRS procedures to seek the best possible result for you within the bounds of the law.

How The Tax Attorneys at Moskowitz LLP Can Help in Tax Court.

Our experienced tax law firm will represent you through the entire Tax Court process, from preparing and filing your petition to representing you in court proceedings. Our services include:

• Pre-Trial Planning: We thoroughly review the IRS’s findings and audit reports, gathering critical evidence and identifying legal arguments to challenge the government’s position. Our goal is to uncover errors in the IRS’s determinations and develop a comprehensive defense strategy.
• Litigation Expertise: Our tax attorneys have deep knowledge of the rules and procedures specific to the Tax Court, allowing us to present your case effectively, with written briefs, oral arguments, and/or by introducing witnesses.
  Every aspect of your case is carefully prepared and presented.
• Negotiation for Settlements: Often, the pressure of litigation can lead to favorable settlements outside of court. We use the possibility of trial as leverage to push for negotiated resolutions that provide you with the best possible outcome, within the bounds of the law.
• Appeals and Higher Court Representation: If needed, our tax attorneys are prepared to take your case beyond Tax Court and into appellate courts, providing that every option is exercised to secure a favorable outcome.

Litigating a tax dispute can seem intimidating, but when handled strategically, it can be one of the most effective tools in a tax attorney’s arsenal. With Moskowitz LLP’s experienced Tax Court representation, you can turn an IRS dispute into an opportunity to obtain your best possible solution within the bounds of the law, safeguarding your financial future.

Why Moskowitz LLP?

Experience. Steadfast Advocacy. Tailored Defense.

Our tax attorneys possess deep knowledge of tax law and have years of experience working in the tax system. This collaboration provides us with unique insights into the intricacies of tax court procedures, allowing us to craft strategies that are both technically sound and aggressively defensive. Call our San Francisco office now at 415-394-7200 to schedule a consultation regarding your matter, or contact us through our website and we will reach out to you.