Low-cost representation of taxpayers with controversies before the U.S. Tax Court
TAX ATTORNEYS & UNITED STATES TAX COURT PRACTITIONERS | TAX LAW INSTITUTE
OUR COMMITMENT
No one wants to litigate in U.S. Tax Court... it is too costly. So, if you've received a tax deficiency notice, we'll advocate on your behalf before the IRS Independent Office of Appeals to reduce what you owe, and we'll do so for a low flat fee. Then we'll negotiate with IRS Counsel and try to settle. If unsuccessful, then we'll represent you or your business in U.S. Tax Court, where we will seek an out-of-courtroom settlement, or we'll prosecute the IRS and go to trial for a low flat fee. No billable hours. No additional costs. And we have a track record of 'win-win, no losses' before the IRS and in U.S. Tax Court.
- We know that deficiency litigation can sometimes be overwhelming.
- We are dedicated to providing you with help when you receive an IRS notice of deficiency. If you don't feel like you understand your options, just ask, and we will work to find a resolution that quickly settles the matter with the IRS. We'll do our best to negotiate a settlement with the IRS's Independent Office of Appeals. You wouldn't need to appear.
- And if the Appeals officer is unmoved and litigation is our only option, we'll explain all the steps and outline all the costs before we recommend you proceed. All the while trying to keep the door open for a behind-the-scenes settlement.
A Focus on Results
- First, we'll work with you to develop a plan to achieve the results you need. Through our understanding of the Internal Revenue Code of the U.S. Treasury Department and your understanding of the circumstances, we will craft a path to successful negotiations and settlement - please know that litigation will be avoided at all costs.
- We will engage every indulgence to encourage cooperative service during our interactions with IRS representatives and the Office of Chief Counsel.
- We are especially sensitive to the number of billing hours tax practitioners can accrue, as well as the ever-mounting expenses that can build during evidentiary collection and research, negotiations, settlement attempts, and sometimes the inevitable pre-trial and litigation processes. For these reasons, we propose a low-cost flat fee so the client can budget payment before we render services.
- We will explain our strategy in detail, listen to your assessments, address your doubts, do our best to assuage your concerns, and then await your informed consent before we proceed. If you come to us with private counsel, then we will listen to their opinions as well. But at the end of the day, we must be sure that you are comfortable with us being in charge. After all, practice in the U.S. Tax Court occurs within our legal domain.
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Step One | Consultation
Contact us for a no-fee phone consultation with our Tax Law Scholars, Tax Attorneys, CPAs, IRS-Approved Enrolled Agents, and United States Tax Court Practitioners. Meet the TLI Litigation Services Group... let us help you figure out your best next steps. The sooner you have a plan of action, the better your chances of taking the correct steps to get the results you want from the IRS and United States Tax Court, and possibly avoid litigation altogether. Continue reading to learn about the procedural steps we must take to remedy your tax liabilities
Below is the 3-step procedural process in U.S. Tax Court. We also define the U.S. Tax Court and the United States Tax Court Practitioner.
United States Tax Court Defined
United States Tax Court
The United States Tax Court is headquartered in Washington, D.C. It is a specialty court that exclusively hears tax law cases. The U.S. Tax Court hears tax deficiency cases - cases in which the IRS asserts that the taxpayer has underpaid his, her, or their tax liability. Prepayment of the proposed tax deficiency is not a prerequisite to litigating in Tax Court. Counsel must know the IRC, the rules of practice and procedure, disclosure rules, and the FRE as applied by the Court.
Pictured is a United States Tax Courtroom, and above, is the United States Tax Court Building at Washington D.C.
United States Tax Court Practitioner Defined
A United States Tax Court Practitioner aka Tax Litigation Counsel, aka Tax Litigation Counsel, is a qualified non-attorney, typically an IRS-approved tax professional, e.g., a CPA or EA, who has passed a rigorous bar examination, received litigation training, and been vetted by the Court and admitted to practice exclusively in and before the United States Tax Court. They provide attorney-equivalent representation in tax litigation. They are authorized legal practitioners before the U.S. Tax Court. They represent taxpayers - individuals, partnerships, corporations, estates and trusts - during legal proceedings held in U.S. Tax Court. Because of their specialized tax accounting skills, litigation training, and stringent IRS approval and practice requirements, tax clients often choose USTCPs over tax attorneys to handle deficiency matters, civil fraud offenses, and other complex tax controversies that move into U.S. Tax Court.
Practice & Procedural Steps
PETITIONS
HEARINGS & TRIALS
DOCKETED APPEALS
- If you've received a '30-day/150-day letter,' it means the IRS has determined that you have a tax deficiency and owe back taxes.
- If you contact us immediately after you receive the letter, we can advise you on what to do. Remember, because you are living outside the U.S., you have fewer than 150 days to respond. The clock starts on the date the IRS mails the 150-day notice.
- If you can document how and why you believe the determination is unjust, then we may be able to challenge the deficiency determination in the U.S. Tax Court.
- First, you must authorize us to represent you (POA), and we will provide a retainer agreement that includes an estimate of our fees.
- Afterward, we will prepare and file the petition with the Court clerk. We will represent you when your case is sent to the docketed appeals (IRS). We will try to reach a settlement with the appeals officer at the hearing that follows.
DOCKETED APPEALS
HEARINGS & TRIALS
DOCKETED APPEALS
- We collect from you all documents that are relevant to your case and that are cited in the notice of (tax) deficiency. Then we conduct our research, evaluate what we discover, and transmit the supportive findings that we deem to be evidentiary to the Appeals attorney who gets assigned to your case.
- We will represent you at the impending hearing before the IRS independent Office of Appeals, where we will attempt to settle your case with the assigned officer. The hearing is your last opportunity to resolve the tax controversy without litigation, so it is best attended only by us, your legal representatives. You will be well-briefed afterward.
- If we cannot reach a settlement, we will send your case back to the Tax Court. We will then consider the feasibility of proceeding to trial in and before the U.S. Tax Court; meanwhile, we will continue to seek any opportunity to reach a pre-trial settlement with the U.S. government attorneys at any point thereafter.
HEARINGS & TRIALS
HEARINGS & TRIALS
HEARINGS & TRIALS
- No one wants to litigate. It is expensive and time-consuming and will require you to be present in the United States. However, we will represent you in and before the U.S. Tax Court and argue your tax matter if we deem the facts of your case to be properly documented and warrant a trial.
- But we will try, right up to the day of trial and during the trial, to reach a settlement. Nevertheless, we will not shy away from a trial if the IRS counsel is unmoved.
- Supervised by our Tax Litigation Counsel, our team of United States Tax Court Practitioners, CPAs and IRS-approved enrolled agents and specialists in forensic tax accounting, fraud defense and auditing - all experienced federally-authorized tax practitioners with various expertise- will work diligently to organize the facts of your case and get you ready (to give witness testimony) for your proceedings. We will prepare all trial documents, decide on the best evidence, and aggressively prosecute your case.
The Tax Law Institute at Washington, DC
Litigation Services & Tax Advisory
1717 N Street NW Washington, DC 20036
+1 (202) 800-9230
"Dedicated to advancing public education and the public interest before the IRS and U.S. Tax Court"
Copyright © 2001-2026 Tax Law Institute Inc.- United States Tax Court Practitioners & Tax Attorneys. We provide Legal Education of Federally-Authorized Tax Practitioners, Pro Bono Legal Services and Federal Tax Litigation Services as a public service - All Rights Reserved. The Tax Law Institute is an IRS Approved Provider of Continuing Education (CE), RS7E4, in Federal Tax Law and Tax Bar and Trial Preparation. TLI is approved to prepare federally-authorized tax professionals, who may claim the federally authorized tax practitioner privilege. Under the law, the term 'federally authorized tax practitioner' (FATP) means an individual authorized under Federal law to practice before the Internal Revenue Service where the practice is subject to Federal regulation under 31 U.S.C. § 330. The Tax Law Institute has entered into an agreement with the Internal Revenue Service, to meet the requirements of 31 C.F.R., § 10.6(g), covering maintenance of attendance records, retention of program outlines, qualifications of instructors, and length of class hours. This agreement does not constitute an endorsement by the IRS as to the quality of the program or its contribution to the professional competence of the enrolled individual. Send mail to - Registered Agents Inc. for the Tax Law Institute Inc. - 1717 N Street, N.W., Ste. 1, Washington, D.C. 20036. Telephone +1.202.403.0599.
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Low-Cost Representation in Tax Court & Tax Advisory
If you do receive a notice of deficiency from the IRS for back taxes, it would be prudent to let us petition the U.S. Tax Court on your behalf. Or, if you've already filed then let us represent you and wait for the case to be sent to the IRS Independent Office of Appeals, where we can possibly settle for less money and avoid any litigation. We've had great success with Appeals and have a 'win/no loss' record before the Court. Or, we can reduce your tax with an OIC. We cite amazingly low flat-fees to fit your budget that can be easily paid online, one-time, and you're done.