What is a Tax Controversy?

tax problemIf you are tagged by the Internal Revenue Service for failure to file a tax return, or your annual FBAR, you have stepped into something that is both a noun and a verb—a tax controversy.


The term tax controversy is used to describe the action around any tax problem. If you put a taxpayer in a Zoom call with an IRS auditor and a stack of contested tax documents, there is bound to be a controversy. So, tax controversy can be just another term to describe the pretty common disagreements that occur between those that pay and those that collect taxes.


A tax controversy is also a noun which describes an important field of law practiced by tax professionals who focus on tax disputes. Here it is not the issues around a tax problem, but a unique practice area of law for attorneys who help taxpayers challenged by specific problems with (usually) the IRS. Some examples include the following:

  • Representation before the IRS on matters involving a civil tax audit: When taxpayers receive an audit letter from the IRS, they have choices. Answer or ignore the letter? Talk to a business associate who has been through the same thing? Talk to a tax attorney? Contact the IRS and give them all the documents they are asking for and hope for the best? An audit letter initiates what could become a tax controversy. Depending on how the matter is handled, the audit could be straightforward and conclude with explanation if needed, or, it could go south and lead to more questions and a broadened review. The best option is to contact an experienced tax lawyer up front to gain the education and guidance you need on how best to respond. Depending on the nature of the tax controversy, you can use a tax lawyer to represent you throughout IRS proceedings, or to offer guidance as you work through the issue with the IRS.
  • Pursuit of a refund, Offer in Compromise, or other tax status: If your asset and wealth profile is complex, your business dealings may generate the need for interaction with the IRS. This could involve a refund, a big write-off, or the discovery of a substantial error. If you make use of the IRS option called an Offer in Compromise, talk to a tax attorney for help preparing your submission. Issues with interest calculation, appeals, compliance problems, international tax irregularities, or employment classifications can trigger tax controversies with significant consequences if not handled appropriately.
  • Criminal tax charges and strategies for resolution: An IRS criminal tax investigation is probably the highest profile type of tax controversy—it also has the most impact on your life if not handled by an attorney who understands how to work with the IRS to mitigate damage to your credibility, career, liberty, and of course, your assets.


A tax controversy can be a lot of things, including a lot of trouble. When you have questions or are contacted by the IRS—speak with a knowledgeable tax attorney.


Aggressive legal representation if you face allegations of tax fraud

With offices in Cleveland and Chicago, the tax attorneys at Robert J. Fedor, Esq., deliver experienced representation when you are challenged with an employment tax dispute, tax audit, or a criminal tax charge. Call us at 800-579-0997 or contact us online when you need a tax lawyer you can count on.


Understanding Tax Fraud