Annapolis Tax Controversy and Disputes Lawyer

Trial-tested tax controversy and disputes lawyers committed to thorough preparation in every matter.

Receiving a notice from the Internal Revenue Service or the Comptroller of Maryland can be a significant source of concern for individuals and business owners. These notices, however, are rarely resolved by inaction. At Crepeau Mourges, our Annapolis, MD tax lawyer practice represents individuals, business owners, executors, and trustees in disputes with federal and state taxing authorities. Founding partner Brian J. Crepeau is a tax attorney, Certified Public Accountant, and Certified Fraud Examiner. Founding partner Brandon N. Mourges is board-certified in Tax Law by The Florida Bar. We welcome the opportunity to discuss your matter during a complimentary case review.

Tax Controversy and Disputes Lawyer Annapolis

What constitutes a tax controversy?

A tax controversy is a disagreement between a taxpayer and a federal, state, or local taxing authority concerning the amount of tax owed, the validity of a filing, or the accuracy of reported information. Controversies may originate from a routine examination, a statutory notice of deficiency, an assessed liability, a lien or levy, or a criminal investigation. Many disputes also develop from prior tax planning and compliance decisions, while others arise in Maryland Tax Court proceedings, real property assessment appeals, or worker classification matters.

While the term “dispute” implies an exchange between two opposing positions, these proceedings are governed by procedural rules and statutory deadlines that often influence outcomes as substantially as the underlying facts. A tax controversy and disputes lawyer in Annapolis addresses both the substantive and procedural components of these matters.

Types of Tax Controversy and Disputes Cases We Handle in Annapolis

Tax controversies vary widely in scope and complexity. Some involve routine examinations that resolve within months. Others extend across multiple years and progress from examination to administrative appeal and, ultimately, to litigation. Our Annapolis, MD tax attorneys represent clients across this full continuum and adjust the strategy based on the procedural posture of the matter.

• IRS audits and examinations. The audit process may proceed through correspondence, office interviews, or field examinations at a business location. We respond to information document requests, attend interviews on behalf of clients, and challenge proposed adjustments when the facts and the law support that position.
• IRS Office of Appeals matters. Following the conclusion of an audit with a proposed deficiency, taxpayers are typically entitled to administrative review by the Office of Appeals. A significant number of cases reach resolution at this stage. We prepare the protest, develop the legal and factual framing of the issues, and negotiate on behalf of the client.
• U.S. Tax Court litigation. When administrative remedies are exhausted, the U.S. Tax Court is frequently the appropriate forum for further proceedings. The deadlines associated with Tax Court petitions are statutory and unforgiving, and procedural missteps can foreclose substantive rights.
• Maryland state tax controversies. Disputes with the Comptroller of Maryland proceed under their own procedural framework. We represent clients in matters involving Maryland income, sales and use, admissions and amusement, and other state-level assessments.
• Tax collection disputes. Once a tax has been assessed, collection activity may follow. This often involves wage levies, bank levies, liens, or Trust Fund Recovery Penalty assessments against responsible officers. For business owners, these matters frequently intersect with business taxation obligations such as payroll and sales tax compliance.
• Criminal tax investigations and defense. Tax matters may transition from civil to criminal posture under certain circumstances. We represent individuals and businesses under criminal tax investigation by the IRS or the Department of Justice. Early intervention often shapes the trajectory of the matter.
• Innocent spouse and joint liability relief. Spouses filing joint returns are generally subject to joint and several liability for the resulting tax obligations. Statutory pathways to innocent spouse relief exist where the facts support eligibility. We evaluate the circumstances and pursue the appropriate form of relief.
• Property tax assessment appeals. Maryland real property assessments are not always reflective of accurate valuation. We represent commercial property owners in administrative appeals and, where appropriate, in proceedings before the Maryland Tax Court.

Why Choose Crepeau Mourges for Tax Controversy and Disputes in Annapolis, MD?

At Crepeau Mourges, tax controversy representation is a central focus of our practice rather than an ancillary service. Both founding attorneys have devoted their careers to disputes with federal and state taxing authorities, which allows us to identify procedural opportunities and substantive defenses with efficiency.

Decades of Federal and Maryland Controversy Work

Brian J. Crepeau concentrates his practice on federal and state tax controversy matters involving individual and corporate taxpayers. He represents clients in administrative disputes before the Internal Revenue Service and the Comptroller of Maryland and litigates matters before the United States Tax Court. Mr. Crepeau is a Certified Public Accountant and Certified Fraud Examiner who earned his Juris Doctor at American University, Washington College of Law. Brandon N. Mourges has been recognized as a Rising Star by Super Lawyers and received the J. Ronald Shiff Memorial Pro Bono Award from the Maryland State Bar Association in 2015.

Court Admissions That Match the Cases We Handle

Tax disputes proceed through different forums depending on the nature and posture of the matter. Mr. Mourges is admitted to practice in Maryland, Florida, Pennsylvania, Virginia, the District of Columbia, the United States Tax Court, the United States Court of Federal Claims, and the United States District Court for the District of Maryland. He is also a member of the American Association of Attorney-CPAs. Our work as Annapolis tax lawyers extends across the full life cycle of a dispute, from initial notice through final resolution.

Understanding Tax Controversy and Disputes Cases

Liability, Penalties, and Procedural Posture

A tax controversy generally involves three interrelated components: the underlying liability asserted by the taxing authority, the associated penalties and interest, and the procedural posture of the matter. The procedural component frequently carries more weight than clients initially anticipate. A matter pending before IRS Appeals follows a substantially different path than one proceeding to Tax Court. A representative engagement may involve:

• The underlying tax liability asserted by the Internal Revenue Service or a state taxing authority
• Civil penalties, including accuracy-related, failure to file, failure to pay, and fraud penalties
• Statutory interest, which accrues daily on outstanding balances
• Trust Fund Recovery Penalty exposure for officers and other responsible persons of a business
• Information return penalties associated with international reporting forms such as 5471, 8865, and 3520
• Collection enforcement actions, including federal tax liens and levies

Liability is rarely the only consideration of substance. Penalties frequently exceed the underlying tax. Procedural decisions made early in a controversy often have a disproportionate effect on the ultimate resolution. Determinations regarding whether to extend the assessment period, whether to pursue Appeals, or whether to file directly in Tax Court each influence the range of available outcomes.

What Are Some Important Aspects in Your Tax Controversy Case?

Several factors consistently shape the resolution of a controversy matter. None is particularly novel, but each carries substantive weight.

• Deadlines. Many tax procedures operate on strict statutory timelines that cannot be extended through informal request.
• Documentation. Positions supported by contemporaneous records and well-organized substantiation are evaluated very differently than those without.
• Procedural posture. Whether a case sits in examination, in Appeals, or in court materially affects strategy and available remedies.
• Counterparty dynamics. The majority of controversies resolve through negotiation, and the professional relationship with opposing counsel or the assigned agent influences that process.
• Related exposure. Other open tax years, pending collection issues, or prior litigation can affect what is achievable in the current matter.

We address each of these areas during the initial consultation. Our objective is to provide a realistic and candid assessment of the case rather than a generalized overview.

Tax Controversy and Disputes Case Timeline

Every controversy follows its own course, though most progress through comparable stages. The total duration depends substantially on whether the matter remains administrative or advances to litigation.

• Initial contact, often through a notice from the Internal Revenue Service or Comptroller of Maryland
• Information gathering, document review, and preparation of the protest or formal response
• Administrative review with the IRS Office of Appeals or the equivalent state office
• Filing in the U.S. Tax Court or another court of competent jurisdiction if administrative remedies do not resolve the matter
• Pretrial discovery, motions practice, and trial preparation
• Settlement, trial, or other final disposition

A straightforward examination may conclude within several months. A criminal investigation or significant civil matter may extend over multiple years. We coordinate the work with your accountant, prior counsel, or financial advisor where appropriate to ensure consistency and efficiency.

What Should You Bring to Your Tax Controversy Consultation?

Please bring whatever documentation you have received and any additional records you can readily locate. We will identify any remaining information required during the initial meeting.

• Any notices, letters, or correspondence from the Internal Revenue Service or state taxing authorities
• Copies of the relevant tax returns at issue
• Records supporting the positions taken on those returns
• A timeline of relevant events, even in summary form

Most consultations last approximately one hour. At its conclusion, you will have a clearer understanding of your position, the realistic options available, and the next procedural steps. The case review is provided at no cost, and there is no obligation to retain our firm following the consultation.

Important Maryland Legal Resources for Tax Controversy and Disputes Cases

Federal and Maryland authorities publish guidance that may assist taxpayers in understanding procedures, deadlines, and required forms. Individuals working with a tax lawyer in Annapolis on a controversy matter may find these references useful as preliminary sources, though they do not substitute for legal advice on a specific case.

• The Internal Revenue Service publishes guidance and forms used throughout audits, administrative appeals, and collection proceedings.
• The IRS Independent Office of Appeals provides administrative review of unagreed examination matters.
• The U.S. Tax Court hears federal tax disputes following the issuance of a statutory notice of deficiency.
• The Comptroller of Maryland administers the assessment and collection of state taxes.
• The Taxpayer Advocate Service is an independent organization within the Internal Revenue Service that assists taxpayers with unresolved issues.

These sources provide a useful baseline for general understanding. They are not a substitute for case-specific counsel. We consult these resources regularly as part of our practice and recommend them as reliable points of reference.

Reach Out to Crepeau Mourges to Schedule a Consultation

A tax controversy is rarely as severe as it may initially appear, and it is rarely a matter best handled without counsel. Contact us to schedule a complimentary case review with a tax attorney Annapolis clients consult during significant tax matters. We will explain the procedural posture of your case, present realistic options, and outline what to expect going forward.