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Tax Controversies

Graves Garrett has a nationwide tax litigation practice that is built upon the unique depth and breadth of experience gained by working both inside and outside of government. The attorneys of Graves Garrett routinely handle civil and criminal tax issues for taxpayers. These issues arise during administrative levels with the IRS, or in civil and criminal tax investigations or prosecutions.  Recognizing that one tax matter can involve both civil and criminal considerations, Graves Garrett relies on its attorneys’ comprehensive experience leading criminal and civil tax prosecutions and investigations for the U.S. Department of Justice to provide clients with valuable insights and practical strategies to effectively navigate and resolve their tax problems.

This experience includes civil and criminal tax matters involving a range of issues, including (i) unreported income, (ii) nonfiler enforcement, (iii) undisclosed offshore assets, (iv) tax return preparers, including complaints involving the IRS’s Office of Professional Responsibility, (v) employment taxes, related trust fund recovery penalties, and worker classifications, (vi) excise taxes, (vii) taxpayer, tax promoter and tax preparer penalties, (viii) IRS administrative procedures (i.e., examinations, appeals, collections and summons enforcement proceedings), (ix) IRS bankruptcy claims, federal and state tax bankruptcy dischargeability, and bankruptcy fraud, (x) valuation disputes, including family limited partnerships, conservation easements and other property interests, (xi) wrongful disclosures and inspections, (xii) IRS whistleblower claims, (xiii) Bank Secrecy Act compliance and (xiv) identity theft.

With regards to taxpayers with undisclosed offshore assets, our firm has successfully led clients through the series of the IRS Offshore Voluntary Disclosure Programs (“OVDP”), bringing them into compliance with the IRS and avoiding any criminal prosecution. Taxpayers can voluntarily disclose their previously unreported offshore assets through the OVDP, as well as separate streamlined offshore programs available for certain qualifying taxpayers. Unlike the IRS’s OVDPs from 2009 and 2011, which have closed, the current OVDP and the separate streamlined programs do not have a deadline. However, the OVDP penalty rate may increase and the IRS may discontinue either program at any time.

Additional information regarding the IRS’s OVDP program can found by clicking here.

If you or your business are facing an audit, dealing with serious civil or criminal tax issue or have undisclosed offshore assets, please contact our firm for our advice and assistance.

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