IRS Audits & Appeals
FMH has significant experience defending taxpayers during IRS audits/exams and at the Office of Appeals. Our clients range from business entities to individuals, trusts, estates, and tax-exempt organizations. Our engagements cover a wide variety of substantive tax issues involving income, estate and gift, employment, international, and excise taxes.
Whether we are engaged at the beginning of the audit, or after other attempts at resolution have failed, our team knows how to explore approaches from multiple angles to achieve the best result for our client.
FMH represents taxpayers in a variety of international tax issues including both planning and controversy matters.
We advise U.S. citizens and green card holders on the tax consequences of living and working abroad, and also assist non-resident aliens with issues involving owning property in the U.S. or earning income from within the U.S. We advise clients on FIRPTA, FATCA, FDAPI/ECI, chapter 3 and 4 withholding, and other compliance issues.
Our team also assists U.S. taxpayers with compliance issues involving foreign financial accounts or assets. This includes streamlined disclosures and other disclosures involving unreported foreign assets or income (e.g., Forms 3520, 3520-A, 5471, FBARs, and others).
If international tax planning or controversy issues arise, we combine our international tax knowledge with our tax controversy experience to defend tax reporting positions and to help craft a defensible tax plan for our clients with international issues.
FMH represents clients in a variety of tax collections matters, including those clients who are facing IRS liens and levies.
We assist taxpayers in obtaining installments agreements, offers in compromise and the resolution of tax liens (whether a discharge of property from tax lien, or release, withdrawal, or subordination of the tax lien).
When the IRS is knocking at your door threatening collection action, it can be scary. Let our team of experienced tax attorneys allay your fears and work with you and the IRS to reach a resolution. Our inside experience having worked for the government coupled with our years of experience navigating the administrative arm of the IRS provides peace of mind to our clients that their case is in the best of hands.
FMH represents clients in all types of tax litigation before various courts, including the U.S. Tax Court, Federal District Courts and Bankruptcy Courts, and State Courts. We handle civil and criminal tax cases, trust, estate, and probate litigation. Our clients include a variety of business entities, tax-exempt organizations, and individuals.
If your case involves taxes, we can handle it. Some of the types of cases we handle include captive insurance companies, conservation easements, FBAR penalties, debt versus equity issues, economic substance doctrine, tax return preparer injunctions, fraudulent transfers, trust fund recovery penalties, summons enforcement, change of accounting methods, refund suits and many others.
We often help our clients avoid tax litigation altogether but are prepared to successfully represent our clients when it is in the client’s best interests to try the case. We look forward to working with you on your potential (or current) litigation matter and will endeavor to make the process efficient and effective for you.
State and Local Taxation
FMH assists clients with various state and local tax matters, including income taxes, sales taxes, documentary stamp taxes, ad valorem taxes and many others.
We represent clients before the Florida Department of Revenue, in administrative adjustment hearings, and before counties in value adjustment board hearings.
We look forward to working with you and helping you navigate the complexities of state and local substantive and administrative issues so you can rest at ease.
IRS “Hot Topics”
The IRS often devotes significant resources to what it perceives as “abusive” transactions motivated by tax incentives or benefits. Unfortunately, taxpayers who have entered into legitimate transactions are often caught up in the IRS’s wide exam net regarding these identified transactions. At FMH, we can help you navigate these complex (and sometimes intimidating to non-tax attorneys and clients) exams.
We have experience assisting clients in navigating these exams, including cases involving cryptocurrency, microcaptives, and conservation easements.
Penalties & Enforcement
FMH defends taxpayers in a variety of penalty and enforcement matters. Our work includes helping taxpayers seek abatements of domestic and international penalty assessments.
We assist taxpayers who are facing trust fund recovery penalties, seeking innocent spouse relief, facing employment tax penalties, and otherwise facing IRS enforcement actions.
We have represented a variety of clients facing tax return preparer investigations or penalties under Sections 6694, 6695, 6700, or 6701.
FMH also helps taxpayers with unfiled tax returns, often going back many years. We assist our clients in coming back into compliance, whether through voluntary disclosure or other options, so they do not have to worry about IRS audits or enforcement.