On the surface, your tax return looks neat and tidy. We put your numbers in the right slots, and our typefaces fit nicely into the IRS tax forms.
But when you and the IRS disagree about an item on your tax return, you need more than numbers in pretty fonts in the right slots. You need authority on your side to either win your case or avoid a penalty.
This is where we come in. We first look to the Internal Revenue Code, IRS regulations, and IRS pronouncements. Often, we find what we need there.
But if not, we then turn to court decisions, because they can contain valuable authority to convince the IRS that your tax position is correct. There are many courts at different levels. What court gives you the best ammunition in a fight with the IRS?
A rough listing, in order:
- U.S. Supreme Court
- U.S. Circuit Court of Appeals (in your circuit)
- U.S. Tax Court, U.S. Court of Claims, or U.S. District Court (in your district)
- Circuit Court of Appeals or U.S. District Court outside of your jurisdiction
If we can find your situation in a positive outcome from one of these courts, we have a huge leg up convincing the IRS that your deduction is correct.
But let’s say that we don’t find a case with true authority that contains your facts and that the IRS would have to follow. The second choice is any case in which the taxpayer won and with facts like yours, because such a case gives us strong arguments that we can usually use to obtain a satisfactory solution for you.