Tax Controversy

When you receive a notice from the IRS, the Colorado Department of Revenue, or any other taxing authority, the stakes are real and the process can be overwhelming. At Lanphier LLP, we provide experienced, strategic representation at every stage of the tax controversy process -- from initial audit defense through administrative appeals and, when necessary, litigation before the United States Tax Court.

Our tax controversy practice benefits from a unique partnership with Dennis M. Lanphier, P.C. Dennis holds both a CPA license and a law license, which means our firm can offer a level of representation that most CPA firms simply cannot match. Where a typical accounting firm must refer clients to outside counsel when a dispute escalates, we handle the entire process in-house -- providing continuity, efficiency, and the peace of mind that comes from working with advisors who know your situation inside and out.

Our approach to tax controversy is grounded in preparation, strategy, and a thorough understanding of both the substantive tax law and the procedural rules that govern disputes. We know how the IRS and state agencies operate, how their agents are trained, and what they are looking for. That knowledge allows us to position our clients for the best possible outcome at every stage.

IRS Audits

Audit defense begins long before the first meeting with the examining agent. Our preparation-focused approach ensures that you walk into every audit fully prepared, with organized documentation, a clear understanding of the issues, and a strategic plan for the examination. We handle both in-person and correspondence audits.

IRS Appeals

When an audit produces results you disagree with, the IRS Appeals Office offers an important opportunity to resolve the dispute without going to court. We represent clients through the appeals process, presenting well-supported positions and negotiating toward favorable settlements.

IRS Tax Court Petitions

If a dispute cannot be resolved through audit or appeals, filing a petition with the United States Tax Court preserves your right to challenge the IRS determination before an independent judicial body. Dennis's law license enables us to file and litigate Tax Court petitions directly.

Payroll Taxes & Trust Fund Recovery

Payroll tax disputes carry unique risks, including personal liability for the trust fund recovery penalty. We help business owners and responsible parties navigate these high-stakes matters and defend against assessments.

Foreign Asset Reporting Issues

Foreign asset reporting penalties can be severe, and the IRS has made international compliance a top enforcement priority. We help clients resolve reporting deficiencies and defend against proposed penalties related to FBAR, FATCA, and other international information returns.

Colorado Department of Labor Audits & Appeals

State-level disputes require an understanding of Colorado-specific rules and procedures. We represent businesses facing audits and appeals from the Colorado Department of Labor, helping to resolve classification disputes, unemployment tax assessments, and related issues.