Worth Law Group represents clients who are the subject of a tax audit initiated by either the Internal Revenue Service (federal) or the Department of Revenue (state), primarily when there is a technical law issue or the tax amounts are substantial. We also fulfill requests for Private Letter Rulings and Advance Ruling Requests on behalf of the client when proper legal compliance is uncertain.
The tax attorneys at Worth Law Group have successfully represented hundreds of clients in tax related disputes with the Internal Revenue Service or the Washington State Department of Revenue and other Washington State agencies. In most cases, our clients and/or their tax return preparer have simply made a mistake in preparing of a tax filing. More often we are able to negotiate a settlement that minimizes penalties or results in a “no change” report by convincing the audit examiner that the client’s position is correct. This involves years of experience in working with the taxing authorities as well as building relationships with the examiners that are founded on trust. While the audit examiners and their supervisors know they have a formidable foe when doing business with a Worth Law Group client, they inherently trust our word.
Occasionally we correct a reporting error or omission by a client in a tax return by filing a request for a Private Letter Ruling. For example, assume the tax law provides that in order to take a certain tax filing position, the taxpayer must make a formal election. The taxpayer fails to make the election but continues to file tax returns as if the election had been made. Often federal regulations will provide relief if the taxpayer discovers the omission and files a Private Letter Ruling request within a specified period of time in addition to submitting a reasonable explanation of the omission. At Worth Law Group, we have significant experience and success in obtaining favorable private letter rulings on behalf of our clients.
Sometimes our clients venture into a transaction or line of business where the federal or state tax treatment is unclear. If we believe there is both lack of clarity in the law and significant tax exposure, we will often recommend submitting an Advance Ruling Request to fully set forth the nature of the transaction or activity, our interpretation and request for the agency’s agreement with our client’s position. This gives our clients peace of mind and helps to avoid the risk of incurring an additional liability at some unknown and perhaps inconvenient time in the future.