Client service is our top priority
James Kutten’s Tax Controversy Law Firm is a solo tax practice designed for your needs. You will never be dispatched to an associate, junior partner, paralegal, or attorney who does not have experience or the expertise to represent you in a manner best suited to solve your problem. The federal tax law is extremely complex.
At my law firm, your only contact will be with an experienced tax controversy attorney. Put the law on your side by hiring an attorney with knowledge, experience, and expertise in the specific area in which you need help to resolve your problem with the Internal Revenue Service.
Representation at all levels
You should retain an attorney who is well versed in the substantive tax law, tax procedural laws, knows all levels of IRS employees, has tax litigation experience, and well suited to represent you before the IRS agency (examination, collection, criminal investigation, IRS Appeals Office; IRS National Office), U.S. Department of Justice, and before the courts, especially the United States Tax Court.
Mr. Kutten is well equipped to represent you before the IRS at all levels. Mr. Kutten has ample experience litigating before the United States Tax Court. Mr. Kutten will utilize his experience to negotiate
Fair fees with no surpriseswith the IRS to resolve your case in an efficient manner. If necessary Mr. Kutten will be prepared to litigate your case before the U.S. Tax Court (or other judicial venue).
Mr. Kutten’s fees are reasonable considering what is at stake. You need an experienced tax controversy attorney who can guide you and advise you.
My fees can be structured by the hour or a flat fee arrangement. My more than thirty years of experience as a Senior Attorney with the Office of Chief Counsel Internal Revenue Service, I am well qualified to represent you.
Law Practice Limited To Federal Tax Controversy Representation
IRS Examination, Collection, Criminal Tax Investigation
- Income Tax (individual, corporation, partnership, trust, or other organization)
- Innocent Spouse Relief (relief from a joint income tax return liability)
- Estate and Gift Tax (family limited partnership tax valuation discount and numerous other issues)
- Employment Tax (responsible officer withholding tax liability; independent contractor v. employee — employment tax liability)
- Penalty Relief (delinquency, negligence, substantial understatement, valuation misstatement, civil tax fraud, and other penalties)
- IRS Collection Issues (IRS lien, levy, seizure, installment agreement, offer in compromise, subordination, discharge, and other collection alternatives)
- IRS Criminal investigation (before the Internal Revenue Service and the United States Department of Justice)
- Whistleblower Representation (an informant may be eligible for a substantial reward)
Criminal Tax Investigation
Representation before the IRS Criminal Investigation Division (special agent) and representation before the U.S. Department of Justice, Tax Division
Representation will focus on the following:
- limiting government access to the taxpayer’s records
- where appropriate assert constitutional defenses and limit the government’s access to document production and testimony
- determine whether the IRS conclusions are correct (i.e., if the IRS is relying upon an indirect method of proof analysis, a thorough understanding of the methodology is critical to the defense)
- review all facts to negate evidence that the taxpayer intended to file a false tax return (willful behavior)
- procedural defenses
- criminal defense representation must also focus on sentence factors, if found guilty or a guilty plea, which will mitigate a prison sentence and focus on probation.