We represent clients in complex disputes with taxing authorities, bringing a strategic, litigation-ready mindset from the outset. Our focus is on resolving controversies efficiently while preserving optionality for escalation when necessary.
Representation in IRS examinations and high-risk audits
Advocacy before the IRS Independent Office of Appeals
U.S. Tax Court and federal tax litigation
Sensitive and high-exposure matters, including fraud allegations
Penalty defense and abatement strategy
Voluntary disclosures and compliance remediation
State and local tax disputes
KNOW ALL OUR CAPABILITIES
If you’re being audited, do not respond alone or hand over documents without understanding what the IRS is really after – get representation early, because how the first stage is handled often decides the outcome. A tax attorney can communicate with the IRS on your behalf, control the flow of information, and preserve your right to appeal. OCP Tax Law represents clients in disputes with taxing authorities with a litigation-ready mindset from day one.
Yes. You can challenge an IRS determination through the IRS Office of Appeals and, if necessary, in U.S. Tax Court – and simply disagreeing with the amount owed is a valid reason to contest it. Acting within the deadlines on the notice is critical, because missing them can forfeit your best options. OCP Tax Law resolves controversies efficiently while preserving the option to escalate when it strengthens your position.
In a dispute, a tax attorney provides attorney-client privilege, courtroom credibility, and a strategy built for negotiation and litigation – protections an accountant generally cannot offer. Your accountant knows your numbers and is a valuable part of the team, but a controversy is a legal proceeding. OCP Tax Law brings both together, combining legal advocacy with accounting depth.
The IRS generally has 10 years from the date a tax is assessed to collect it, and usually three years to audit a return – but those clocks can pause or extend, and there is no time limit at all in cases of fraud or unfiled returns. Because the rules depend on your specific facts, it’s worth having an attorney review your account transcripts. OCP Tax Law handles both current disputes and complex or legacy tax matters.
YOUR TAX STRATEGY SHOULD BE STRUCTURED,
DEFENSIBLE & TRULY ALIGNED WITH YOUR BUSINESS GOALS.
A tax controversy attorney does more than respond to the final stage of a dispute. The administrative record begins much earlier. What the taxpayer submits, how an issue is framed, and which deadlines are preserved can affect later options in Appeals or litigation.
An IRS audit attorney or IRS examination attorney can organize the factual record before sending documents or explanations. A tax dispute attorney should also identify which requests relate directly to the issue under examination and where additional context may be needed.
An IRS audit letter can request information, schedule an examination step, or communicate a proposed adjustment. Different notices create different consequences. An IRS notice of deficiency is especially important because it can start the period for filing a petition in the United States Tax Court.
An IRS appeals attorney usually works with a dispute that already has an examination history. Clear documentation and consistent legal positions can make the unresolved issues easier to evaluate. Weak or contradictory explanations can make later advocacy more difficult.
A tax litigation attorney must work from the procedural posture and evidence that exist when the matter reaches court. Litigation strategy therefore benefits from decisions made earlier in the controversy. Court is not a separate universe from the audit record.
Some disputes begin with filing errors, international reporting, or transaction positions. Others later create collection pressure. OCP Tax Law can direct compliance issues to Tax Compliance and collection matters to IRS Debt Resolution while the controversy page remains focused on challenging or defending the underlying tax position.
