PKF O’Connor Davies provides tax controversy services, as well as IRS and state and local representation for individuals, businesses and law firms managing complex federal, state, local and international tax matters. Whether you need our expertise in responding to a tax notice, managing an examination, pursuing an administrative appeal or facing a matter with litigation implications, we stand ready to help.
Leadership Experience Inside the IRS
Practice Leader Kelly Morrison-Lee has held senior positions with the IRS Chief Counsel and IRS Commissioner, including serving as Special Counsel to the National Taxpayer Advocate and Senior Advisor to the Chief Tax Compliance Officer. She has tried cases before the U.S. Tax Court, managing docketed and non-docketed matters involving bankruptcy, governmental immunity, lien and levy procedures, state and local property law, civil and criminal penalties, equitable estoppel and summons enforcement.
That firsthand knowledge of IRS practices and procedures informs every engagement. Our team draws on backgrounds in enforcement, tax planning, technical regulatory matters and guidance writing to develop clear, tactical strategies that help clients avoid and resolve conflicts.
Meet Our Professionals
Kelly Morrison Lee
Yevgeny Antonov
Evgenia Belyavskaya
Thomas Kinder
Nicholas Rochedieu
Representation Before the IRS, State and Local Tax Authorities
Protecting the taxpayer is central to every engagement. We work closely with clients to clarify their rights at each stage of the process, take the appropriate procedural steps and identify a practical resolution for each client or client business. When required, we provide representation before the Internal Revenue Service and state and local taxing authorities.
For individuals, businesses and law firms — particularly those with international tax exposure — we provide tax due diligence, administrative support and litigation assistance. We also apply the Firm’s tax planning capabilities to help reduce the potential for future controversies.
State and Local Tax Controversies
Tax controversies are not limited to the IRS. State and local tax authorities conduct their own examinations, assessments and enforcement actions, and multistate businesses and individuals with residency or nexus questions are frequently subject to them. Working with the Firm’s State and Local Tax (SALT) practice, our Tax Controversy team supports clients responding to state and local notices, examinations and appeals and coordinates federal and state positions when a matter spans both.
Our Tax Controversy Services
IRS Examinations, State and Local Examinations, Correspondence and Enforcement
Supporting taxpayers through each stage of the process, our services include:
- Private letter rulings and determination letters
- Risk assessment and audit readiness
- IRS and state examination management and audit defense
- IRS correspondence and enforcement response
- Federal administrative practice and procedure
- Cross-border transactions and reporting requirements
- Information returns
- Employment taxes and withholding regimes
Appeals, Collections and Penalty Abatement
Our professionals assist clients with:
- Administrative appeals and alternative dispute resolution (ADR)
- Private letter rulings
- Choice of administrative forums
- Penalty and interest abatement
- Collections alternatives, including release of levies and liens and deferred payment arrangements
- Payment obligation management
- Domestic and offshore voluntary disclosures and voluntary compliance programs
- Late election relief
- Statutes of limitations issues
- Taxpayer rights protections
- Identity theft and identity verification issue protection
Tax Risk Assessment and Technical Tax Matters
Our tax controversy services also include:
- Tax risk assessment, mitigation and quality control
- Opinion letters and due diligence services
- Privacy and disclosure laws
- Check-the-box filing requirements
- Bipartisan Budget Act (BBA) and Tax Equity and Fiscal Responsibility Act (TEFRA) partnership procedures
- Credits and incentives
- SALT advisory and enforcement changes
- Whistleblower awareness
Law Firm, Investigation and Litigation Support
Our Tax Controversy team serves as a connection point for multidisciplinary client needs, bringing together tax compliance and investigations specialists with the Firm’s forensics, litigation and valuation professionals. We regularly support law firms and their clients in matters with tax implications, including:
- Law firm and litigation referral consultation
- Expert opinions
- Government and white-collar investigations
- Shareholder dispute litigation
- Kovel agreements
- Forensic accounting with tax implications
- Litigation support services
From the first notice through examination, appeal and resolution, we support taxpayers at every step of the administrative process — clarifying obligations and timelines, protecting taxpayer rights and evaluating options to reduce or mitigate penalties and interest.
Discuss an IRS or Tax Controversy Matter
Whether you are responding to a notice, managing an examination, considering an appeal or seeking to reduce future tax risk, contact our Tax Controversy team to discuss how we can help.
FAQs
What should I do if I receive an IRS notice?
Review the notice promptly, note any response deadline to ensure that you timely protect your taxpayer rights and keep it with your records. An experienced advisor can explain what the notice means, your obligations and timeline and the options available before you respond. PKF O’Connor Davies helps clients evaluate and respond to IRS notices, correspondence and enforcement actions. If you are a current client, contact your engagement team immediately.
Can PKF O'Connor Davies represent clients before the IRS and state tax authorities?
Yes. When required, PKF O’Connor Davies provides representation before the Internal Revenue Service as well as state and local jurisdictions, supporting clients through examinations, appeals and collections.
What types of tax controversy matters does the team handle?
The team assists with IRS and state examinations, correspondence and enforcement response, administrative appeals, collections alternatives, penalty and interest abatement, domestic and offshore voluntary disclosures, private letter rulings and determination letters, tax risk assessment and matters involving litigation support.
Does the team support matters involving international tax exposure?
Yes. For individuals, businesses and law firms with international exposure, the team provides tax due diligence, administrative support and litigation assistance, including cross-border transaction and reporting requirements.
Can the team support law firms and matters with litigation implications?
Yes. The Tax Controversy team brings together tax compliance and investigations specialists with the Firm’s forensics, litigation and valuation professionals to support law firms and their clients, including expert opinions, Kovel agreements and government and white-collar investigations.