Tax Controversy

Dwyer Law specializes in tax controversy, representing individuals and corporations in disputes with the Internal Revenue Service. Our tax controversy practice is driven by significant government and trial experience, allowing us to define early strategies, anticipate government tactics, and position clients for the strongest possible outcome.

Our work spans civil audits, administrative appeals, and defending clients in civil actions involving alleged tax violations, with a particular focus on fraud related issues. We also represent clients in every phase of criminal tax matters—from initial IRS inquiries and interactions with the Department of Justice to defense in federal district court.

Some of our experience includes:

Ongoing representation of a tax professional in a criminal investigation related to certain advice given in connection with tax positions regarding Malta and Puerto Rico.

Ongoing representation of various individuals who did so-called “silent disclosure” of foreign bank accounts instead of participating in the IRS’ Offshore Voluntary Disclosure program.

Ongoing representation of a company engaged in the sale and marketing of what the IRS calls conservation easements.

Ongoing representation of a former high-level manager at a large employer in connection with a criminal investigation related to alleged failure to collect and pay over employment taxes and alleged immigration violations.

Successfully represented an individual in a civil action pending in Federal District Court, in which the individual is alleged to have willfully failed to file a foreign bank account report.

Represented an individual in an audit that occurred after the individual “opted-out” of the offshore voluntary disclosure program. The audit resulted in the lowest possible non-willful penalty.

Represented a South Florida corporation in a federal grand jury investigation related to alleged tax fraud. Jed was able to resolve this “bet the company” matter with no criminal charges against the corporation.

Successfully stopped the Internal Revenue Service from providing a foreign government with United States bank records for purposes of a foreign tax collection proceeding. The Internal Revenue Service sought the records pursuant to a Tax Treaty, and Jed was able to convince the Department of Justice to withdraw the request and not seek the records.

Represented a certified public accountant in a federal grand jury investigation of alleged tax fraud, that resulted in no criminal charges.

Represented various clients in connection with sensitive Internal Revenue Service audit matters, including offshore account audits, audits related to unreported income, and audits involving allegations of civil fraud.

These examples are offered only to show experience and not as a prediction of any potential results of a potential client’s matter. Each case is different and requires different approaches, that will and can, result in different results.