Dallas Tax Attorneys

Experienced Dallas Tax Lawyers Representing Individuals and Companies in Complex Federal Tax Matters

Non-compliance with the Internal Revenue Code can expose U.S. taxpayers to substantial liability for back taxes, interest, and penalties. Violations of other federal tax laws, including those pertaining to the disclosure of offshore assets, can have similar consequences. For U.S. tax code taxpayers who have concerns about compliance—or who are facing scrutiny from the Internal Revenue Service—working closely with an experienced Dallas tax lawyer can be essential for securing a favorable resolution and tax planning.

At Oberheiden P.C., our law offices attorneys have extensive experience advising and representing clients in connection with high-stakes federal tax matters. We practice law to represent individuals and companies in the Dallas, Texas area, throughout the United States, and worldwide. If you have questions about proactively resolving a past filing mistake or reducing your (or your company’s) tax debts, if you are facing an IRS audit, criminal tax investigations, or IRS CI investigation, or if you need experienced tax counsel for litigation or an appeal in United States Tax Court, we encourage you to get in touch with an experienced IRS Tax Attorney at our law office to find out what we can do to help.

Our Areas of Practice

Within our federal tax practice, we represent individuals and companies in all IRS-related matters. This includes (but is not limited to) providing representation in the areas of:

IRS Audits

The IRS uses its authority to audit taxpayers to assess and enforce compliance with the Internal Revenue Code (IRC), Foreign Account Tax Compliance Act (FATCA), Bank Secrecy Act (BSA), and other applicable laws and regulations. While the IRS audits hundreds of thousands of returns annually, facing an audit is far from a routine or straightforward process. Audits can present substantial risks for both individual and corporate taxpayers; and, to avoid unnecessary liability, taxpayers targeted by the IRS need to execute an informed defense strategy.

We represent clients during correspondence audits, office audits, and field audits. While the IRS conducts audits to assess and enforce compliance in all areas, it has recently prioritized areas such as:

• Cryptocurrency and gaming-related tax issues
• Improper credits, deductions, and exemptions
• Offshore disclosure violations
• Payroll tax issues
• Underreporting taxable income

If you have received an audit letter from the IRS (or if your company has received an audit letter), a Dallas tax attorney at Oberheiden P.C. can assess your (or your company’s) risk and help you determine how best to proceed. Your lawyer can then work with the IRS on your behalf to help steer the audit toward a favorable resolution that avoids unnecessary liability.

IRS Audit Appeals

If you have recently gone through an IRS audit and you disagree with the IRS’s determination of your (or your company’s) liability, the next step is to consider an appeal. The IRS’s Independent Office of Appeals hears challenges to audit determinations in most cases, though taxpayers have the option of going straight to the U.S. Tax Court in some cases.

Our Dallas tax lawyers can determine if you have grounds to file an appeal; and, if so, we can take appropriate action on your behalf. We can also help you decide if pursuing an alternate means of tax relief or resolution makes sense given the present circumstances. Regardless of the circumstances at hand, you have clear options if the IRS miscalculated your (or your company’s) liability or you (or your company) cannot afford to pay—the key is to choose the option that affords the greatest opportunity to secure a favorable resolution while also ensuring that you keep your other options on the table.

IRS CI Investigations

IRS CI investigates suspected criminal violations of the IRC, FACTA, BSA, and other federal statutes. Criminal investigations present substantial risks for companies, owners, executives, and other individual taxpayers—including risks for both fines and imprisonment. Some of IRS CI’s current enforcement priorities include:

• Underreporting and underpayment of federal tax liability
• Using abusive tax schemes to evade federal tax liability
• Failing to timely remit payroll taxes held in trust
• Employee Retention Credit (ERC) and Paycheck Protection Program (PPP) fraud
• Intentional offshore disclosure violations (international tax fraud)

If you have received any form of communication from IRS CI, it is imperative that you engage experienced counsel immediately. Federal criminal tax-related investigations can move quickly; and, by the time you hear from IRS CI, there is a good chance that Special Agents already have substantial evidence in their possession. A Dallas tax lawyer at Oberheiden P.C. can intervene in IRS CI’s investigation, assess your (or your company’s) risk, and execute a defense strategy focused on resolving the investigation without federal criminal charges being filed.

Federal Tax Litigation

Along with audits and investigations, we also represent taxpayers in federal tax litigation. This includes appeal-related litigation in the U.S. Tax Court as well as criminal litigation resulting from IRS CI investigations. With a team that includes several former U.S. Department of Justice (DOJ) trial attorneys, we are well-versed in the DOJ’s litigation tactics and strategies, and we rely on our experience and insights to protect our clients’ interests at all stages of the litigation process.

Tax Relief and Resolution

We also assist individual and corporate taxpayers with seeking tax relief and resolving tax controversies before they face scrutiny from the IRS or IRS CI. The IRS administers several programs that allow taxpayers to resolve their tax debt for less than the full amount they owe, and both IRS and IRS CI administer programs that allow taxpayers to avoid scrutiny by coming forward on their own initiative. Our Dallas tax attorneys assist individuals and companies with pursuing options such as:

• Innocent Spouse Relief
• IRS Penalty Relief
• Offers in Compromise
• Tax Installment Agreements
• Voluntary Disclosures

These are just examples. We also assist taxpayers with seeking tax relief and resolving tax controversies through a variety of other means as well. This includes specialized means such as taking advantage of the IRS’s Streamlined Filing Compliance Procedures. These procedures are specifically available to U.S. taxpayers who need to resolve non-willful offshore disclosure violations (i.e., failure to file an FBAR or IRS Form 8938). If you have questions about using any available means to come into compliance and avoid scrutiny from the IRS, we encourage you to speak with a Dallas tax attorney at Oberheiden P.C. in confidence.

Put our highly experienced team on your side

Dr. Nick Oberheiden

Founder

Attorney-at-Law

Lynette S. Byrd

Former DOJ Trial Attorney

Partner

Brian J. Kuester

Former U.S. Attorney

Hon. Kevin McCarthy

55th Speaker, U.S. House of Representatives (ret.)

Government Consultant

Mike Pompeo

Of Counsel

Former U.S. Secretary of State

John W. Sellers

Former Senior DOJ Trial Attorney

Linda Julin McNamara

Federal Appeals Attorney

Nicholas B. Johnson

Former Prosecutor

Roger Bach

Former Special Agent (DOJ)

Chris J. Quick

Former Special Agent (FBI & IRS-CI)

Michael S. Koslow

Former Supervisory Special Agent (DOD-OIG)

Ray Yuen

Former Supervisory Special Agent (FBI)

FAQs: Resolving High-Stakes Tax Controversies with the IRS

Speak with a Dallas Tax Attorney at Oberheiden P.C. in Confidence

If you would like to speak with a senior tax attorney at Oberheiden P.C. in confidence, we invite you to get in touch with our tax law firm. To schedule a complimentary initial consultation over the phone or at our offices in Dallas, TX, please call 888-680-1745 or request an appointment online today.