Townsend & Jones represents clients in the area of tax law commonly referred to as tax controversy. Tax controversies include audits, appeals, collections, criminal tax matters (including grand jury matters), and civil and criminal litigation. Our representation also includes advising as to the tax aspects of business transactions and how they should be reported on tax returns.
Audits and Appeals
Townsend & Jones believes that a taxpayer should only litigate against the IRS after all other alternatives of resolving a tax dispute have been exhausted. In audits conducted by the IRS, Townsend & Jones represents clients and works with their accountants in resolving an IRS audit in the manner most favorable to our clients. However, Townsend & Jones strives to resolve the matter at the audit level and prepare to proceed to the Appeals Office or to litigation, if the audit is not resolved in a favorable manner to the client. Townsend & Jones believes that the Appeals Office generally offers a favorable venue to resolve disputes short of litigation.
Townsend & Jones frequently represents taxpayers in a broad range of tax issues in the United States Tax Court, United States District Courts, United States Bankruptcy Courts, United States Court of Federal Claims, and United States Courts of Appeals, principally the Fifth Circuit which includes Texas.
Townsend & Jones represents individuals and corporations who are targets of criminal tax and other types of financial investigations by the IRS and by the United States Department of Justice, including the Tax Division and local United States Attorneys Offices. Townsend & Jones represents clients in administrative and grand jury investigations and trials in United States District Courts, as well as in IRS civil audits which have the potential to be referred to the Criminal Investigation Division. A significant part of the criminal tax practice involves negotiating with the Department of Justice regarding whether criminal charges will be pursued, which charges will be pursued and, if appropriate for the client, negotiating the best possible plea agreement. Townsend & Jones also represents clients in appeals from criminal cases. In addition, Townsend & Jones represents clients prior to investigation or prosecution in assessing whether to make a voluntary disclosure to mitigate or eliminate the possibility of criminal investigation or prosecution. Townsend & Jones has been significantly involved in the IRS voluntary disclosure practice since the founding of the firm, but has been substantially involved in the special IRS voluntary disclosure initiatives related to foreign financial accounts. Through those initiatives, our clients have mitigated or eliminated their criminal prosecution risk and, where appropriate, reduced their financial penalty exposures for income tax penalties and FBAR penalties.
Townsend & Jones regularly deals with IRS collection personnel, and uses its attorneys’ extensive experience in helping clients resolve IRS collection matters. Depending upon the needs of the clients, Townsend & Jones negotiates installment agreements and offers in compromise, and where appropriate, advises as to the dischargeability of taxes in bankruptcy.
Corporate and Business Law
Incident to the tax controversy practice, Townsend & Jones advises and assists corporations and individual businesses by furnishing general legal services necessary to the proper conduct of their business operations, and represents clients in the purchase and sale of businesses.