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At Calone Law Group, LLP one type of representation we
provide is representation during tax controversies or
audits. A taxpayer's odds of being chosen for audit are
slim, however, if you are one of the unlucky ones it is
not a pleasant experience. When faced with an audit a
taxpayer needs the expertise of a representative that
knows how to deal with the Internal Revenue Service or
any California State taxing authority. At Calone Law
Group, LLP we can provide representation from the outset
of an audit, or representation once the audit has been
completed and the Internal Revenue Service or any
California State taxing authority has determined you owe
additional tax. Simply because you have been told you
owe additional tax by a taxing authority does not mean
they are correct. You do have appeal rights and you
should have the determination challenged if you do not
agree with it. In order to challenge a determination
made by the Internal Revenue Service it is necessary to
petition the United States Tax Court. Our office has
extensive experience in filing petitions with the Tax
Court and obtaining results for our clients. Simply
because a petition is necessary to preserve your appeal
rights does not mean you will incur substantial costs in
a trial. The Internal Revenue Service has a division
called the Appeals Division that will try to resolve a
taxpayer's matter short of litigation. At this Appeals
Division we meet with a representative of the Internal
Revenue Service who is supposed to be impartial and
considers the hazards of litigating a matter and
resolving the matter short of trial. Over ninety percent
of all Tax Court matters are settled in the Appeals
Division without the necessity of a trial. However, once
you go to the Appeals Division you need a representative
who can express your position in such a way as to
persuade the Internal Revenue Service that they do not
want to litigate your matter. Our office has extensive
experience with Tax Court matters and matter resolution
at the Appeals Division. If you have been notified that
you have been selected for audit, or have completed an
audit I encourage you to schedule an appointment with
our office to discuss your options or strategy. Time is
of the essence in these matters and if you have received
a Statutory Notice of Deficiency from the Internal
Revenue Service you must appeal the determination within
ninety (90) days. Therefore, do not delay in contacting
our office for representation. The philosophy of Calone
Law Group, LLP when it comes to audits and tax
controversies follows the eloquent words of Judge
Learned Hand: "Over and over again courts have said that
there is nothing sinister in so arranging one's affairs
as to keep taxes as low as possible. Everybody does so,
rich or poor; and all do right, for nobody owes any
public duty to pay more than the law demands: taxes are
enforced exactions, not voluntary contributions. To
demand more in the name of morals is mere cant."
Commissioner v Newman, 159 F2d 848, (2d Cir. 1947)
(Hand, J. dissenting). At an audit or at the conclusion
of an audit we will make sure you are only paying what
the law demands, and not making any voluntary
contributions.
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