Frisco Tax Lawyers

When the IRS determines that there is a tax deficiency, a tax dispute may ultimately be heard in the United States Tax Court, the United States District Court, or in the United States Court of Federal Claims. We frequently help our clients navigate the procedural options and judicial fora, analyzing the governing law and procedural benefits in formulating a clear strategy.

Freeman Law aggressively represents clients in tax litigation at both the state and federal levels. When the stakes are high, clients rely on our experience, knowledge, and talent to help them navigate all levels of the tax dispute life cycle—from audits and examinations to the trial courtroom to all levels of appeals.

Our Frisco tax lawyers represent taxpayers in audits, tax litigation, and criminal tax investigations on the federal, state, or local level. We are well-versed in the tax controversy process.

Careful planning can provide a means to avoid tax controversies. Identifying tax issues can sometimes mean the difference between a well-prepared tax position and tax-related penalty assessments. Our Frisco tax lawyers regularly guide clients through the private letter ruling (PLR) process and the preparation of disclosures, as well as providing tax opinions and evaluating tax risk.

Our Frisco tax attorneys are regularly engaged to serve as consulting and testifying experts with respect to tax matters.

• audit representation;
• unfiled and delinquent tax returns;
• appeals and collection actions;
• federal and state court tax litigation;
• innocent spouse relief;
• voluntary disclosures;
• removal of liens;
• levies, seizures, wage garnishments;
• offers in compromise;
• installment agreements;
• tax penalty abatement and defense, and
• Freedom of Information Act requests, among other matters.

Freeman Law’s Frisco tax lawyers represents clients in IRS examinations, leveling the playing field. We guide clients through the IRS audit process, formulating an audit strategy and interfacing with IRS revenue agents.

Our Frisco tax lawyers handle audits relating to cross-border issues, such as transfer pricing; offshore insurance; foreign taxes; and controlled foreign corporation status. We represent taxpayers in IRS “wealth squad” audits; TEFRA and BBA partnership audits; and audits focused on economic substance issues, tax accounting issues, corporate acquisitions and divestitures, and other sophisticated IRS examination issues.

Our Frisco tax lawyers, legal team, and tax professionals often interact with the IRS National Office and Treasury Department, preparing ruling requests, engaging in Technical Advice proceedings, and seeking administrative determinations, revenue rulings, and Treasury regulations.

We also utilize Fast Track mediation, Fast Track Settlement conferences, early referrals, post-appeals mediation, and IRS arbitration.

Positioning a tax case for the right resolution, whether through settlement or a verdict, is both an art and a science. Optimal results require skilled advocacy, measured judgment, and a depth of substantive tax knowledge. At Freeman Law, our Frisco tax lawyers draw on our experience and wealth of tax knowledge to advise and guide clients through the entire tax controversy process, building the right strategy to resolve tax controversies from day one.

Freeman Law’s Frisco tax lawyers represents businesses and individuals in a wide range of tax and related disputes, including disputes related to:

• Federal Income Tax
• Estate and Gift Tax
• Employment Tax
• Excise Tax
• Fraud
• International Information Returns
• Foreign Bank Account Report (FBAR) Penalties
• Civil Tax Penalties
• Criminal Tax Prosecutions

Our Frisco tax lawyers provide strategic counseling and seasoned advocacy, finding the best path forward in the most complex and trying of situations. In the process, we provide clients with a voice and work collaboratively to position their case in the most favorable light.

Freeman Law’s Frisco tax lawyers handles matters in the United States Tax Court, the Court of Federal Claims, the Federal District Courts, and the Federal courts of appeal. We also represent clients in state court and at the administrative level.

Because of our unique substantive and procedural knowledge, our Frisco tax lawyers are able to provide a comprehensive approach to the tax dispute resolution process, often collaborating with clients’ existing tax professionals to formulate creative solutions to the most sophisticated tax problems.

We combine skillful representation in the courtroom with sophisticated tax advice, drawing on our vast tax litigation experience.

Globalization is a fact of life in our modern economy, and cross-border activities have become the norm, not the exception. Freeman Law’s Frisco tax lawyers provide experienced counsel with respect to international and offshore tax compliance. We help clients manage, understand, and comply with the tax requirements that come with holding foreign assets; engaging in inbound and outbound cross-border transactions; maintaining ongoing business operations in foreign countries; and various other international complexities.

With recent legal developments such as the Foreign Account Tax Compliance Act (“FATCA”) and the expansion of Information Exchange Agreements among countries around the world, the flow of information and reporting to the IRS and the coordinated enforcement by taxing authorities has never been greater. For many, that means that the risks of non-compliance have never been more real. Freeman Law’s Frisco tax lawyers can help businesses and individuals manage these critical tax risks and make sense of complex international tax compliance rules.

Our Frisco tax lawyers assist clients with international information return compliance and penalties, including:

• Form 5471, Information Return of U.S. Persons with Respect to Certain Foreign Corporations
• Form 5472, Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business
• Form 8938 Statement of Specified Foreign Financial Assets
• IRS Form 3520 Reporting Transactions with Foreign Trusts and the Receipt of Foreign Gifts
• Form 3520-A, Information Return of Foreign Trusts With a U.S. Owner
• Form 926, Return by a U.S. Transferor of Property to a Foreign Corporation
• Form 8865, U.S. Persons and Foreign Partnerships

Freeman Law’s Frisco tax lawyers represent taxpayers facing IRS criminal investigations and prosecutions. We combine unique criminal defense experience with substantive tax knowledge. We often conduct our own investigation, analyzing applicable defenses and addressing ongoing IRS investigations.

Our firm enjoys a national reputation as a distinguished criminal tax defense firm. Our Frisco tax lawyers’ legal team maintains a reputation for integrity and vigorous representations defending criminal tax prosecutions and investigations, often seeking to convince government decision-makers to decline prosecution.

The Supreme Court of the United States is the highest court in the United States’ judicial system. The Supreme Court hears cases involving constitutional challenges and other cases, including tax cases, involving statutory interpretation.

With some exceptions, the Supreme Court hears cases selectively, by granting a writ of certiorari.

Justices of the Court are appointed by the President and confirmed by the Senate for a life term referred to as “justices” and are appointed by the President and confirmed by the Senate for a life term.

Throughout its history, the U.S. Supreme Court has decided a number of landmark federal taxes cases, including:

• McCulloch v. Maryland
• Eisner v. Macomber
• Pollock v. Farmers' Loan and Trust Company
• Pollock v. Farmers' Loan & Trust Company (Rehearing)
• CIC Services, LLC v. Internal Revenue Service
• South Dakota v. Wayfair, Inc.
• Quill Corp. v. North Dakota by and Through Heitkamp
• Pollock v. Farmers’ Loan and Trust Company
• Marinello v. United States
• Cheek v. Commissioner
• Head Money Cases
• Stearns v. Minnesota
• Walz v. Tax Comm'n of the City of New York
• White Mountain Apache Tribe v. Bracker
• Allen v. Wright
• Metropolitan Life Ins. Co. v. Ward

The U.S. Courts of Appeals have jurisdiction to review decisions from the Tax Court and the district courts in the taxpayer’s geographical residence. The United States Court of Appeals for the Federal Circuit reviews decisions from the U.S. Court of Federal Claims.

>Judgements by district courts in tax refund actions can be appealed to one of the eleven regionally-based U.S. courts of appeals or the United States Court of Appeals for the D.C. Circuit. For the Court of Federal Claims, appeals lie to the Court of Appeals for the Federal Circuit, which has national jurisdiction.

There are twelve federal circuits that divide the country into different regions. The Fifth Circuit, for example, includes the states of Texas, Louisiana, and Mississippi. Cases from the district courts of those states are appealed to the United States Court of Appeals for the Fifth Circuit, which is headquartered in New Orleans, Louisiana. Additionally, the Federal Circuit Court of Appeals has a nationwide jurisdiction over specific issues.

Our firm has litigated appellate matters in the federal courts of appeals.

Our Frisco tax attorneys have represented taxpayers in hundreds of cases before the United States Tax Court. The United States Tax Court is an Article I court established to hear tax controversies between the Internal Revenue Service and taxpayers. The Tax Court is based in Washington D.C. and has 19 judges, providing a national forum for the resolution of tax disputes.

Congress established the Board of Tax Appeals under the Revenue Act of 1924. In 1942, the Board’s name was changed to the Tax Court of the United States,” which was later reconstituted as the United States Tax Court.

The Tax Court is established under Title 26 section 7441 of the United States Code, which provides that:

The Tax Court is the primary prepayment tax dispute forum and exercises nationwide jurisdiction.

The Tax Court has jurisdiction to redetermine deficiencies and overpayment in income, gift or estate taxes, and certain excise taxes of private foundations and foundation managers. I.R.C. §6213(a).

The Tax court issues several types of opinions: Bench Opinion; Summary Opinion; Tax Court Opinions; and Memorandum Opinions.

Our Frisco tax lawyers represent clients in tax refund suits in U.S. district court or the Court of Federal Claims. The United States district courts are the only tax trial court where a taxpayer can obtain a jury trial through a refund suit.

District courts are regional-based federal courts of general jurisdiction.

The United States Court of Federal Claims is a United States federal court with jurisdiction over monetary claims against the U.S. government and consists of 16 judges appointed for terms of 15 years. The Federal Courts Improvement Act of 1982 created the modern court.

The court has special jurisdiction under 28 U.S.C. § 1491 to hear claims for monetary damages that arise from the United States Constitution, federal statutes, executive regulations, or an express or implied in fact contract with the United States Government, most notably under the Tucker Act.

• Tax Litigation; Wrongful Seizure. Recovered hundreds of thousands of dollars as lead counsel in suit against United States/IRS and Department of Justice for wrongful collection activities and seizure of assets.
• Tax Litigation; U.S. Virgin Islands. Represented client in Tax Court litigation, challenging IRS proposed assessment denying United States Virgin Islands (USVI) bona fide resident status and tax benefits; obtained concession from IRS and full tax benefits.
• IRS High-Wealth Audits; Puerto Rico. Represented client in IRS “wealth squad” (Global High Wealth Industry Group) audit involving Puerto Rico Act 20/22 benefits; obtained “no-change” audit.
• IRS Tax Representation; Puerto Rico. Represented client in challenging IRS assessment denying Puerto Rico Act 20/22 benefits; obtained reversal and removal of full assessment.
• Tax Litigation. Represented clients in proceedings to quash international tax Formal Document Requests, seeking documentation regarding foreign accounts.
• Criminal Tax Investigation; Non-Prosecution. Represented client in criminal tax referral involving allegations of income tax evasion; “killed case,” obtaining declination to prosecute client from United States Attorneys Office.
• Criminal Tax Investigation; Non-Prosecution. Represented client in criminal tax investigation by IRS Criminal Investigation Division involving allegations of income tax evasion; “killed investigation,” obtaining agreement from IRS CID not to seek prosecution against client.
• Criminal Investigation; Seizure; Non-Prosecution. Represented client under federal investigation for laundering and facilitating cryptocurrency exchanges following government seizure of cash. “Killed case,” and obtained government declination to pursue criminal charges, as well as obtained return of all seized funds.
• State Criminal Tax Investigation; Non-Prosecution. Represented client in state criminal tax investigation and obtained dismissal of charges.
• IRS “SEP” Audit/Investigations. Represented client in Special Enforcement Program (“SEP”) audit/investigation involving millions of dollars of alleged unreported income and several million dollars of unpaid tax and assessments; obtained deal to avoid criminal referral and avoidance of fraud penalties.
• IRS International Penalty Defense and Voluntary Disclosure. Represented client in IRS offshore voluntary disclosure, guiding client through an “opt out” and reducing penalties by hundreds of thousands of dollars through penalty defense.
• IRS Tax Penalty Representation. Obtained penalty abatement and removal of IRS penalties in excess of $14 million.
• Federal Tax Litigation. Represented client in Tax Court, obtaining complete removal of more than $300,000 in tax assessments.
• Innocent Spouse Relief/Penalty Relief. Obtained innocent spouse relief, removing liability for tax liabilities of more than $500,000.
• Innocent Spouse Relief/Penalty Relief. Obtained innocent spouse relief, removing liability for tax liabilities of more than $600,000.
• Innocent Spouse Relief/Penalty Relief. Obtained innocent spouse relief, removing liability for tax liabilities of more than $1,000,000.
• IRS Voluntary Disclosure/Cryptocurrency. Represent client in IRS voluntary disclosure involving multi-million-dollar cryptocurrency holdings.