Atlanta Tax Lawyer Protects Your Business by Defending Your Rights
Comprehensive Federal Tax Services for Small to Medium-sized Companies
There are few areas of the law as complicated as corporate or partnership taxation. Poor tax planning or adverse IRS actions can severely impact a small or medium-sized business. If you are concerned you haven’t been getting reliable advice on taxation, or you have an audit upcoming, Spizzirri Law Offices Company Limited is prepared to help. We handle all tax law matters, including tax law opinions, tax preparation and filing review, IRS and state tax audits, collection defensive measures, and criminal tax defense. Our reputation for integrity and professionalism helps us work effectively even under the most adverse circumstances to resolve tax problems favorably for our clients.
Irs Audit Examination Defense
If the IRS has sent notice it plans to audit your business, you need the assistance of an experienced tax attorney to help you minimize negative consequences, which can include additional assessments, penalties, interest, and even criminal prosecution. Our extensive experience with all areas of state and federal tax law allows me to understand the complicated processes and procedures that accompany an audit. We provide the proactive representation you need to prepare your company for the audit, including sound and effective tax law opinion letters, tax books and records documentation and maintenance and tactical initiatives to support your company’s tax strategies. We serve as your legal representative throughout the audit, defending your tax practices whenever the auditors raise an issue. When errors are uncovered, we can often negotiate a settlement that satisfies tax investigators and avoids an escalation of the controversy.
Fighting for Your Rights in Tax Litigation
In many instances, an optimal result of an audit examination can only be achieved through tax court litigation. When the results of an audit are controversial, you have the right to challenge the auditors’ findings in the U.S. Tax Court, the United States Court of Claims or United States District Court. As a tax litigation attorney with vast experience in tax disputes, Paul can help you through every step of the process. No matter your issue, he has extensive experience in the Tax Court and is prepared to provide you with the zealous advocacy you need.
Defense to Irs Tax Collection Actions
The IRS has aggressive tools at its disposal to collect back taxes and penalties. However, indiscriminate use of such tools, including the filing of tax liens, can restrict your access to the capital. Suddenly you are faced with a Catch 22: use capital to continue operations, so it’s impossible to repay what you owe, or repay your back taxes, but cease business operations. This choice can be even more difficult when tax compliance failures come as a surprise result of an audit examination where previously unknown liabilities for tax, interest and penalties can exceed your ability to pay. Before you let IRS collections force you into bankruptcy, consult a knowledgeable tax defense attorney who can protect your rights.
Providing Criminal Tax Defense in Atlanta
On rare occasions, an IRS audit uncovers discrepancies that prompt investigators to refer criminal charges. Potential penalties are steep, including heavy fines and potential prison time. We provide defense to criminal charges as well as civil tax disputes. Having been with my clients throughout the audit, I can move seamlessly to a defense of criminal charges, including tax fraud or tax evasion. When necessary, we partner with criminal defense counsel, who act as local counsel or litigation partners on substantial cases that can involve a variety of federal or state criminal charges in addition to tax fraud.
Clarifying the Cost-benefit Analysis Of Your Company’s Complex Transactions
If you went to a doctor with a complaint about chest pains, and he told you not to worry because it’s only indigestion, you might want a second opinion. After all, if he’s wrong, you’ve got a great deal to lose, especially if you plan to run a 5K next week. The same logic applies to taxation. If your company is mulling over a development strategy, you need to know if your taxation plan can survive scrutiny from the Internal Revenue Service, or if an alternative tax structure could reduce your exposure further without raising red flags. At Spizzirri Law Offices Company Limited, tax opinion letters constitute a significant part of our business law practice. Client businesses rely on our analysis when making strategic decisions that depend on favorable tax consequences.
Reliable Tax Opinions Facilitate Complex Transactions
The first purpose of a tax opinion letter is to eliminate risk from an upcoming transaction. Suppose your company was considering a merger or acquisition. Because a complex transaction can succeed or fail based on how favorably the IRS treats your tax strategy, there are many stakeholders — from your board to your shareholders to the lender who might extend a line of credit — who want to be certain of the tax implications.
We thoroughly examine the details of a proposed transaction, scrutinize the tax plan, and draft a detailed opinion letter, affirming or denying the legal and factual bases for the tax assumptions in the plan. When our letter declares why we, as a disinterested party, believe the corporation’s proposed tax strategy is meretricious, this result sets shareholder minds at ease, and insulates board members from potential allegations they breached their fiduciary duty in approving the transaction. The company can structure the transaction with confidence and will generally find it much easier to raise capital and at a lower cost. Our clients can often secure prior IRS approval that removes any shadow of controversy from the transaction.
On the other hand, when our tax opinion raises red flags about potential conflicts with the U.S. Tax Code, your company now has actionable intelligence to help you rework the deal on a sounder basis.
Tax Opinions to Protect Your Company From Irs Audits and Penalties
An audit by the IRS is costly, time-consuming, and distracting for your business. When there are questions about the company’s compliance with applicable tax law, we draft tax opinion letters expressing our basis, in law and in fact, for believing your company is likely to prevail on the merits with respect to any significant tax issues. In some cases, this may be enough to obviate the need for an audit. In other cases, it can form the basis for a defense against certain penalties.
The Importance of Impartiality in a Tax Opinion Letter
There are many other reasons your company might want an opinion letter from an Atlanta tax lawyer. It could be a necessary precursor to a contract or a means of determining whether circumstances have triggered certain contractual provisions. However, for this service to have any meaning at all, two conditions must be met.
First, we must preserve our impartiality. We can only draft tax opinions for companies we have not been closely involved with already on tax matters. Second, we must go where the facts lead us. On occasion, our opinions can be contrary to the clients’ desires. Even so, our opinion can supply a basis for remedying the tax controversy.
Let a proactive corporate tax lawyer provide a reliable opinion
A mistaken assumption in your company’s tax strategy can destroy the value of a complex transaction. Before you move forward on your development strategy or engage in a tax dispute with the IRS, let Spizzirri Law Offices Company Limited provide an unbiased opinion of your tax exposure.
To schedule a consultation, call (404) 954-1781 or contact our Atlanta office online.