Massachusetts IRS Tax Audit Lawyer
What exactly might one expect to happen in the event of a tax audit? The answer, as one might expect, is "it depends." In an income tax audit case, for example, some general statements can be made. Especially in those cases in which the audit is one conducted in the field for the examination of the books and records of a business by an IRS Revenue Agent, the agent will be looking to verify that the factual information presented on the return is correct from (a) verification of reported transaction details from records, (b) corroboration of the accuracy of income reported from bank and other financial records, (c) answers to questions relating to disclosures of matters essential to the accuracy of representations made on a return or returns, (d) confirmation of third-party relationships, and (e) reconciliation of expense or capital expenditure to business necessity and use. One is more often than not ill-prepared, at best, to respond to demands for production of financial and tax records, and, moreover, for explanations of how these records support information on an income tax return or returns. Business, banking and tax records enjoy no privilege of non production. Nonperformance is not an option. Time is of the essence. As is the case in an enforced tax collection action, or a matter in which a sense that a criminal tax investigation has or may commence, you cannot see leverage in the situation. You cannot afford anything less than a truely knowledgeable, effective advocate to stand in your shoes as your legal advocate.
Attorney Theodore L. Craft has more than 35 years experience in tax law. He has tried many cases in the United States Tax Court both for the Government and for private clients. He was trained as a trial lawyer by the Office of the Chief Counsel, Internal Revenue Service, National Office, and by the Department of Justice, Tax Division. While Senior Trial Attorney in the Office of the Chief Counsel at the IRS National Office, he was liaison to Department of Justice, Tax Division, for Tax Refund Litigation, and developed complex national tax positions and trial strategies. He has prosecuted and defended numerous criminal tax cases. In his private law practice, he now uses his extensive experience to help clients overcome serious tax problems.
You can depend on Theodore L. Craft to provide you with representation of the highest quality.
Resolving Complex Tax Problems
The practice of Theodore L. Craft focuses solely upon the resolution of civil and criminal tax issues with the Internal Revenue Service or the Department of Justice, Tax Division.
Theodore L. Craft represents clients and their business interests generally in highly sensative tax inquiries, which arise primarily through IRS tax audits. The chief emphasis of his tax law and procedure practice, then, is defending those who stand threatened to lose valuable tax benefits granted to them by Congress. These benefits are secured to them by way of proper procedures, evidence, interpretations of case law in situations similar to their own, and, most importantly, effective written and personal advocacy. He defends those accused of fraudulent practices or criminal tax violations, and defends those charged with tax crimes by way of plea negotiations or, in appropriate cases, trials in federal court. He provides valuable insight into the viability of IRS tax abuse allegations and defends clients in tax shelter and abuse cases, including in non-disclosures of foreign account activity matters investigated by the IRS.
The IRS may attack transactions reported on returns for many reasons. For example, the IRS will deny tax benefit claims relating to what it considers as "shams," that is, transactions entered into solely for tax advantage without economic substance. It may seek to impose income tax upon business owners for "constructive dividends," that is, economic benefits considered to have been received by corporate owners and/or officers on account of uses of business assets and/or income for their personal, undeclared [and often hidden] benefit. Settlements on terms favorable to clients in such cases involve high complexity relative to the substance of the issue and the matching of intuitive negotiation skills based upon procedural knowledge to the matter at hand.
Determined to Prevail
Theodore L. Craft, Esq., LLM, Attorney at Law & Tax Counsel has the knowledge and skills needed to succeed in negotiations with the IRS and in court. These include knowledge of tax statutes and case laws, IRS procedures and trial advocacy skills. As an advisor, advocate and tax defense attorney, Theodore L. Craft is determined to prevail.
In your case, the firm will work to resolve your problem effectively, efficiently and in the most favorable manner possible.
Contact a Boston Tax Law Attorney
For a consultation regarding a tax matter, contact Theodore L. Craft.
