Culp Elliott & Carpenter’s IRS and State Audit and Appeals practice represents corporate and individual clients facing high stakes, complex tax disputes. Our tax lawyers have substantive tax expertise needed to powerfully present cases to the IRS. Clients have confidence in our years of experience dealing with IRS agents during audits and with IRS administrative appeals officers when filing administrative protests. We have been able to achieve favorable settlements for our clients when appropriate under the facts and the law. Client tax departments, closely held business owners, and individual clients hire us because of our track record and our extensive experience.
In audits and appeals cases, our lawyers:
- Help CPA firms develop and present their clients’ cases when audited by the IRS. We also handle IRS audits directly for our own clients.
- File written administrative protests with IRS Appeals if audits are not settled.
- Handle audits and appeals against the North Carolina Department of Revenue and other governmental tax agencies in the Southeast.
The range of our audit matters include:
- Residency status disputes in state income tax cases.
- Innocent spouse tax relief in the context of separation or divorce.
- Company share valuations in federal estate and gift tax disputes.
- Conservation easement qualification and valuation disputes in IRS audit and appeals.
- Reasonable compensation and T&E expense defense in closely held business cases.
- Economic substance issues involving sale/leasebacks, mergers, tax losses and partnership tax controversies.