irs tax disputes
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RICHARD CARPENTER
TAX COURT LAWYER AND PROFESSOR
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NAMED A "SUPER LAWYER" FOR NINE CONSECTUTIVE YEARS (2008 - 2016)
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PUT MY 30 YEARS OF TAX REPRESENTATION EXPERIENCE
TO WORK FOR YOU.

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IRS TAX COURT

The United States Tax Court hears 95% of all IRS tax disputes decided by a Court. Approximately 30,000 petitions are filed with the Tax Court each year. The most important advantage of IRS tax court is you can get your case heard in Court through tax representation, without having to pay the disputed tax in advance.


HOW TO GET INTO TAX COURT

  • You first need a Notice of Deficiency to go to Tax Court to dispute an income tax matter.
  • You only have 90 days after the Notice of Deficiency is mailed to you to file your Petition with the Tax Court in Washington, D.C.  There is also a special 150 day "out of the country" exception rule that may assist you when filing a Tax Court petition.
  • Note, if you file your Petition late, even by 1 day, the Tax Court will not be able to hear your case.

TAX COURT IS COMPLICATED

  • The Tax Court has more than 300 technical rules.  If you overlook certain rules, your case could get dismissed.
  • Under the Tax Court rules, you generally have the burden of proving the IRS wrong.
  • The job of the Tax Court is to determine the correct amount of tax. Thus, it is possible for an unprepared taxpayer to wind up owing more tax than the IRS initially asked for.   
  • Jury trials are not permitted in Tax Court.  

NEVER REPRESENT YOURSELF IN TAX COURT

         The first thing you need to understand is that the IRS attorney represents the Government - not you.  The job of the IRS attorney is to win the case for Government - not to help you win your case. Tax Court judges can also be difficult to deal with. Some IRS attorneys will take advantage of you if they sense that you don't understand the Court rules.  IRS attorneys are specially trained in tax law and they deal with the Tax Court on a regular basis.  On the other hand, you are not trained in tax law and this will probably be your first time in Court.  So, if you represent yourself in Tax Court, the IRS attorney will have a clear advantage over you. Don't make a big mistake by representing yourself in Tax Court.  


SAN DIEGO TAX LAWYER RICHARD CARPENTER IS THE RIGHT TAX LAWYER FOR YOU

  • I have 30 years of experience as an IRS tax specialist.
  • I am the leading San Diego tax court lawyer for a Tax Court case.  
  • I am a Certified Tax Law Specialist by the State Bar of California.
  • I have been named a "Super Lawyer" for the past nine consecutive years - in 2008, 2009, 2010, 2011, 2012, 2013, 2014, 2015 and 2016.
  • For the past 22 years, I have also been a part-time Tax Law Professor at the University of San Diego School of Law. I teach the Tax Court Litigation class using my experience with the IRS Tax Court.  I am the only attorney in San Diego who teaches the Tax Court Litigation class at a law school.
  • I have the trial experience to win your case. 

   If you have a case heading to Tax Court, why would you hire anyone else?

RESULTS

RESULTS . . . that's the bottom line ... what every client is looking for.  

During the past 30 years, I have helped thousands of clients resolve their tax disputes with the IRS.


          A) On January 21, 2016, the U.S. District Court in San Diego dismissed all criminal tax charges against my client.   The Government had previously Indicted my client for structuring of bank deposits to avoid the bank financial reporting requirements.

         B) In a recent 2015 Tax Court case, the IRS was seeking approximately $3,000,000 in additional tax, penalties and interest.  I was able to obtain Innocent Spouse relief for my client…and therefore, she did not owe the IRS any money.  That was a $3,000,000 reduction. 

         C) I was the lead attorney for the Petitioner in David Carreon v. Commissioner (T.C. Memo 2014-6).  The IRS had asserted that my clients - the Petitioner, and his two related corporations - were subject to a 75% civil fraud penalty.  After a trial in U.S. Tax Court, Judge Wherry issued his written Decision.  The U.S. Tax Court ruled that my clients - were NOT subject to a civil fraud penalty.  This was a COMPLETE VICTORY FOR MY CLIENTS.

Despite my strong record of favorable client outcomes during the past 30 years, I refrain from making any case result predictions to you about your tax court case without knowing the complete facts of your case. Each tax case has its own unique set of facts.  I urge you to call me today for a FREE consultation. You can also email me in confidence.


GUIDANCE YOU CAN TRUST

During the past 30 years, many San Diego attorneys, CPA's and other tax professionals have referred their own clients and family members to me for help in resolving their serious tax problems with the IRS and the state of California. These local tax professionals knew that I would do my best to produce the best results possible their clients and family members.

HELP IS AVAILABLE TO YOU NATIONWIDE...

I understand how a Tax Court case can take hold of your life and affect your ability to sleep at night. If you are serious about resolving your tax dispute, I can help you regardless of where you live. Call me, San Diego tax attorney Richard Carpenter, at (619) 696-8607 to discuss your tax situation in complete confidence. Put my 30 years of tax law experience to work for you.

YOU DO NOT HAVE TO FEAR THE IRS WITH ME ON YOUR SIDE.

Hire A "Super Lawyer" With 30 years of Tax Law Experience To Resolve Your Tax Dispute.
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RICHARD CARPENTER
SAN DIEGO TAX ATTORNEY
406 Ninth Ave., Suite 213
San Diego, CA 92101
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Richard

TELEPHONE: 619/696-8607
FAX: 619/696-0126
E-MAIL: rc@irstaxdisputes.com
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San Diego tax attorney specializes in United States Tax Court hearings & tax court petition of federal tax law through tax audits & tax collections, tax appeals, and criminal tax

RICHARD CARPENTER

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SAN DIEGO TAX ATTORNEY
-  Certified Tax Law Specialist
-  30 years tax law
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experience
-  Skilled negotiator, well
-respected, fights for best
-results
-  Tax law professor
-  Named a "Super Lawyer"
-for 9 straight years.
-  Able to communicate
-directly with IRS or
-California on your behalf
-  Reasonable fees, all major
-credit cards accepted
-  Prompt, confidential help
-  Dedicated to defending
-taxpayers against the far and
-powerful reaches of the
-Internal Revenue Service
San Diego tax lawyer
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© 2006-2016 RICHARD CARPENTER, ATTORNEY AT LAW.    ALL RIGHTS RESERVED.

This website (www.IrsTaxDisputes.com) is the legal advertisement of San Diego Tax Attorney Richard Carpenter.
NOTE: the use of "IRS" in our domain name (www.IrsTaxDisputes.com) is not meant in any way to convey any false impression that our law firm is in any manner approved, endorsed, sponsored, or authorized by, or associated with the Internal Revenue Service and/or the U.S. Department of the Treasury.

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