Are you looking for an IRS negotiation and litigation lawyer in Hanover, MD?
At Crepeau Mourges, we provide IRS negotiation and litigation representation guided by over 35 years of combined experience in Hanover and the surrounding area.
If you received a notice of deficiency, a proposed assessment, or an IRS collection action and you believe the government’s position is wrong, you have options. At Crepeau Mourges, our attorneys negotiate with the IRS and litigate tax cases in the U.S. Tax Court and federal district courts on behalf of individuals and businesses. A Hanover, MD IRS negotiation and litigation lawyer at Crepeau Mourges can assess your dispute and pursue the right resolution. Schedule a free consultation to discuss your situation.
IRS Negotiation and Litigation Lawyer Hanover, MD
An IRS negotiation and litigation case involves challenging, resolving, or settling a tax dispute with the Internal Revenue Service through administrative channels or in court. This area of practice covers everything from informal discussions during an audit to formal proceedings before the U.S. Tax Court.
Of the 23,280 cases closed in the U.S. Tax Court in FY 2024, more than 99% were resolved through settlement or default without a trial, according to the National Taxpayer Advocate. The Tax Court holds trial sessions in Baltimore, roughly 15 miles from Hanover. Those numbers confirm what experienced IRS negotiation attorneys already know: most tax disputes are won or lost at the negotiation table, not in a courtroom.
Types of IRS Negotiation and Litigation Cases We Handle in Hanover
Tax disputes with the IRS take many forms. At Crepeau Mourges, we handle IRS negotiations and tax litigation across the full range of controversy matters for taxpayers in Hanover, MD.
- IRS audit. When an IRS examination results in proposed adjustments to your tax liability, you have the right to challenge those findings. We review audit work papers, identify errors in the IRS’s analysis, and negotiate for a reduction or elimination of the proposed changes.
- IRS appeal. If you disagree with an audit result or collection action, the IRS Independent Office of Appeals provides an administrative forum to resolve your case without going to court. We prepare and present appeals for clients facing common tax disputes at every level.
- U.S. Tax Court litigation. When administrative negotiations fail, filing a petition in the U.S. Tax Court allows a taxpayer to challenge a deficiency determination before paying the disputed amount. We handle Tax Court proceedings from pre-trial negotiation through discovery and trial.
- IRS collections. Taxpayers facing enforced collection activity, including wage garnishments, bank levies, and asset seizures, can dispute those actions through Collection Due Process hearings and other administrative remedies.
- IRS tax lien. A federal tax lien attaches to all of your property and damages your credit. We negotiate lien releases, subordinations, and discharges, and challenge improper IRS levies through administrative and judicial channels.
- Offers in compromise. An offer in compromise allows eligible taxpayers to settle their tax debt for less than the full amount owed. We evaluate whether you qualify, prepare the required financial disclosures, and negotiate with the IRS to reach an acceptable resolution.
- Installment agreements. Taxpayers who cannot pay their full tax liability at once may qualify for a monthly payment plan. We negotiate installment terms that fit your financial circumstances and protect you from further collection action while payments are being made.
- Penalty abatement. The IRS imposes penalties for late filing, late payment, and accuracy-related issues. We pursue abatement through reasonable cause arguments, first-time penalty relief, and other available provisions.
Why Choose Crepeau Mourges as My IRS Negotiation and Litigation Lawyer in Hanover, MD?
IRS Tax Controversy Practice in Maryland
Brandon N. Mourges and Brian J. Crepeau co-founded Crepeau Mourges with a concentration in tax controversy and litigation. Mr. Mourges holds an LL.M. in Taxation from the University of Baltimore School of Law and a B.S. in Economics from the Wharton School. He has been recognized as a Rising Star by Super Lawyers, named to Benchmark Litigation’s “40 & Under Hot List,” and received the Readers’ Choice Top Author in Tax award from JD Supra in 2020. He is a member of the Federal Bar Association and the American Association of Attorney-CPAs.
Mr. Crepeau concentrates on federal and state tax controversy and is admitted to practice before the United States Tax Court, as well as in Maryland and Florida. His practice spans over two decades of representing taxpayers in disputes with the IRS and state tax authorities.
Whether your dispute involves an audit challenge, an IRS tax appeal, or full litigation in Tax Court, the experience you want from an IRS tax lawyer in Hanover, MD is the ability to negotiate from a position of strength and to go to trial when the IRS won’t agree to a fair result.
What Is Important To Understand About IRS Negotiation and Litigation Cases?
What Are Important Aspects of an IRS Negotiation and Litigation Case?
The outcome of any IRS dispute depends on documentation, timing, and how well your attorney can identify weaknesses in the government’s position. The IRS follows internal procedures and guidelines, and those rules sometimes work in the taxpayer’s favor when applied correctly.
Factors that shape results in IRS negotiation and litigation include:
- Whether the IRS followed proper administrative procedures during the audit or collection process
- The strength of the factual record supporting your reported position
- Applicable statute of limitations issues that may prevent the IRS from assessing additional tax
- The availability of penalty relief through reasonable cause or first-time abatement
- Whether you have filed all required returns and are in current compliance
Identifying these factors early gives your IRS litigation attorney in Hanover leverage at every stage of the dispute.
IRS Dispute Resolution Options and Potential Outcomes
The IRS provides several administrative and judicial pathways for resolving tax disputes. Understanding these options is an important part of developing an effective strategy.
- Informal negotiation. During or after an audit, taxpayers can work with IRS examiners or their managers to resolve disagreements before a formal determination is issued.
- IRS Independent Office of Appeals. IRS Independent Office of Appeals is the Service’s internal administrative forum for settling disputes without court involvement. Appeals officers have authority to consider the hazards of litigation and settle cases on that basis.
- U.S. Tax Court. Taxpayers who receive a notice of deficiency can petition the Tax Court to challenge the proposed assessment before paying the tax. Most Tax Court cases settle before trial.
- Federal district court or Court of Federal Claims. Taxpayers who have already paid the disputed amount can file a refund suit in either of these courts.
- Alternative dispute resolution. The IRS offers programs including fast-track settlement and post-appeals mediation for certain eligible cases.
The right path depends on the amount at issue, whether the criminal tax investigation risk is present, and whether you want to challenge the IRS before or after payment.
What Is the IRS Negotiation and Litigation Case Timeline?
IRS tax disputes vary widely in duration. Simple audit disagreements may resolve in a few months through informal negotiation. Cases that proceed to the IRS appeals process typically take six months to over a year. Tax Court litigation can extend one to three years, depending on complexity.
The general progression of an IRS tax dispute follows this pattern:
- IRS issues a proposed adjustment, notice of deficiency, or collection notice
- Taxpayer responds with a protest or request for reconsideration
- Case moves to the IRS Independent Office of Appeals for conference
- If unresolved, taxpayer files a petition in U.S. Tax Court or pays and files a refund suit
- Settlement negotiations continue during litigation, with trial as a last resort
Having an IRS negotiation and litigation attorney in Hanover, MD working on your case from the outset allows you to preserve rights, meet deadlines, and position the dispute for the strongest possible outcome.
What Should You Bring to Your IRS Negotiation and Litigation Consultation?
Providing thorough documentation at your initial meeting helps your attorney evaluate the dispute and recommend a course of action. Gather the following if available:
- IRS notices, letters, or proposed adjustments you have received
- Tax returns for the years in dispute
- Supporting records such as receipts, invoices, bank statements, and cancelled checks
- Prior correspondence with the IRS, including any audit reports or examination results
- Information about any informal resolution attempts already made
Your attorney will review this information, assess the merits of your position, and advise whether negotiation, appeal, or litigation is the most effective strategy.
Hanover Tax Courts and IRS Administrative Resources
IRS tax disputes originating in Hanover, MD can be resolved through the IRS Independent Office of Appeals or litigated in the U.S. Tax Court, which holds trial sessions at the Edward A. Garmatz Federal Building in Baltimore, approximately 15 miles from Hanover. Refund suits may be filed in the U.S. District Court for the District of Maryland, which sits in Baltimore and Greenbelt.
The IRS Independent Office of Appeals resolves the majority of tax disputes without court involvement. For cases that require judicial review, the proximity of the Baltimore Tax Court sessions provides convenient access to federal litigation for Hanover taxpayers.
Reach Out to Crepeau Mourges to Schedule a Consultation
If you are facing an IRS tax dispute and need an experienced negotiation and litigation attorney in Hanover, MD, Crepeau Mourges can help. We offer free consultations where we evaluate your case, explain the available resolution options, and outline a strategy for moving forward. The sooner you involve a tax controversy lawyer, the more leverage you retain. Contact us to schedule a confidential consultation.
