IRS Tax Dispute Attorneys in New York, New Jersey & Federal Court

In a Tax Dispute With the IRS? Protect Your Finances and Rights.


Not every tax matter is criminal. Many individuals and businesses face civil tax disputes with the IRS, New York State Department of Taxation and Finance, or New Jersey Division of Taxation. These disputes may begin with an audit, notice of deficiency, or disputed tax bill. If not resolved properly, they can escalate into liens, levies, wage garnishments, or even criminal referrals to the IRS Criminal Investigation Division.

Effective representation during a tax dispute can mean the difference between resolving your case fairly and facing years of financial hardship.

Common Types of IRS Tax Disputes

  • IRS Audits: Disputes over income reporting, deductions, or credits.
  • Notice of Deficiency / Tax Assessments: Challenges to additional taxes claimed by the IRS.
  • Payroll Tax Disputes: Issues with withheld taxes or classification of employees vs. independent contractors.
  • Unpaid Tax Liabilities: Delinquent tax debts leading to liens or levies.
  • Penalties & Interest: Disputes over excessive penalty assessments or abatement requests.
  • Foreign Account Reporting (FBAR): Disputes over disclosures of offshore accounts and penalties under the Bank Secrecy Act.
  • Innocent Spouse Relief: Disputes over joint tax liability when one spouse claims lack of knowledge.

IRS Dispute Resolution Options

  • Administrative Appeals: Challenging IRS findings before the Independent Office of Appeals.
  • Tax Court: Filing a petition in the U.S. Tax Court to dispute an IRS determination before paying the tax.
  • District Court or Court of Federal Claims: Suing for a refund after paying disputed taxes.
  • Offers in Compromise: Negotiating with the IRS to settle tax debt for less than the full amount owed.
  • Installment Agreements: Structuring payment plans to resolve liability without financial ruin.
  • Penalty Abatement: Requesting relief from penalties due to reasonable cause or IRS errors.

State Tax Disputes in New York & New Jersey

  • New York: Disputes are handled by the Department of Taxation and Finance and the Division of Tax Appeals. Issues often involve sales tax audits, residency disputes, or corporate tax assessments.
  • New Jersey: Disputes may be heard by the Division of Taxation or appealed to the New Jersey Tax Court. Common issues include income tax adjustments, sales/use tax disputes, and business tax liabilities.

Why Tax Disputes Matter

Even if no criminal charges are involved, tax disputes can carry devastating financial and personal consequences:

  • Tax liens against homes or businesses
  • Wage garnishments or frozen bank accounts
  • Seizure of property or assets
  • Damaged credit and loss of financial stability
  • Escalation to criminal referral if the IRS suspects fraud

Defense Strategies in Tax Disputes

  • Reviewing IRS audit procedures for legal or factual errors
  • Challenging the accuracy of assessments, calculations, or assumptions
  • Providing documentation and expert testimony in support of deductions or positions taken
  • Negotiating settlements, compromises, or payment plans
  • Protecting clients from escalating to criminal prosecution whenever possible

Why Skilled Representation Matters

Tax disputes involve complex rules, strict deadlines, and adversarial negotiations with government agencies. The IRS and state tax departments are backed by trained auditors, attorneys, and revenue officers whose job is to maximize collections. Without skilled representation, taxpayers are at a serious disadvantage.

An experienced tax dispute attorney in New York, New Jersey, and federal practice can level the playing field, protect your rights, and work toward the most favorable resolution possible.