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Tax Controversies and Appeals


Carlile Patchen and Murphy represents businesses and individuals in state and federal income and employment tax audits, at all administrative levels of the Internal Revenue Service, U.S. Tax Court, and Ohio Department of Taxation.

Such representation includes defending against responsible person liability for employment and sales taxes; negotiation of innocent spouse relief; defending against reclassification of contractors as employees; obtaining release of liens and relief from levies; avoiding the application of the “hobby loss rules” to prevent the disallowance of business deductions; negotiation of installment payment plans; defending against a challenge to a nonprofit organization’s exemption from Federal income tax due to the organization’s partnering with a for-profit entity; and the negotiation of offers in compromise with state taxing authorities as well as the Internal Revenue Service. We receive regular referrals from accountants and other lawyers and have had great success in reversing adverse audit results upon appeal within the IRS and negotiating favorable resolutions with state taxing authorities.

Our tax lawyers are well versed in state and federal voluntary disclosure programs that provide significant tax relief, including Ohio income, sales and use tax disclosure programs, the federal employee classification disclosure program and the federal foreign bank account disclosure program.

We have the skill and experience to work out a negotiated settlement with the IRS and state taxing authorities when it is in the best interests of our clients, combined with the ability to litigate.