A tax controversy attorney with more than 30 years' experience as a tax controversy attorney with respect to the three main IRS functions: audit, collection, and criminal tax investigation. James Kutten - Office of Chief Counsel Internal Revenue Service, Senior Attorney over 30 years' experience. Mr. Kutten provided legal advice to Internal Revenue Service employees IRS Revenue Agents Revenue Officers Special Agents Appeals Officers Appeals.
The majority of Mr. Kutten's legal career was as a senior attorney with the Office of Chief Counsel Internal Revenue service, where he advised IRS employees in thousands of cases, many involving cutting edge complex tax issues. Law Practice Limited To Federal Tax Controversy Representation. Income Tax Innocent Spouse Relief Estate and Gift Tax Employment Tax Penalty Relief IRS Collection Issues IRS Criminal investigation Whistleblower.
The majority of Mr. Kutten's legal career was as a senior attorney with the Office of Chief Counsel Internal Revenue service, where he advised IRS employees in thousands of cases, many involving cutting edge complex tax issues. Law Practice Limited To Federal Tax Controversy Representation. Income Tax Innocent Spouse Relief Estate and Gift Tax Employment Tax Penalty Relief IRS Collection Issues IRS Criminal investigation Whistleblower.
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James Kutten is a seasoned litigator in the U.S. Tax Court. Mr. Kutten has 30 years' experience litigating cases as a senior attorney with the Office of Chief Counsel Internal Revenue Service. Mr. Kutten's prior litigation involved tough and difficult cases (i.e., indirect method of proof income analysis, federal estate tax valuation issues, tax shelters, partnership transactions, and civil fraud penalties, just to name a few).
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.
Every day the Internal Revenue Service audits individuals and organizations to determine what the IRS describes as their correct tax liability. Generally the IRS audit process involves taxpayer cooperation and agreed case. However disagreement with the examining agent occurs. The taxpayer has procedural rights during and after a tax examination.
The Internal Revenue Service collection power is unlike any other creditor. Upon assessment (recording on the books of the IRS that the taxpayer owes the tax, penalties, and/or interest), there is an immediate lien (unrecorded) against all of the taxpayer's property and right to property. The IRS generally sends the taxpayer a notice to pay the additional tax.
The Internal Revenue Service routinely asserts penalties. Penalties are a multiple of the additional tax or unpaid tax, and can be very substantial. In some circumstances the IRS does not properly assert tax penalties.
In certain circumstances, IRS penalties can be mitigated or abated by a well prepared tax controversy attorney who can present your case in the correct manner, arguing that the penalty should not be asserted, or arguing that the taxpayer's tax reporting is based upon reasonable cause.A tax preparer penalty assessment may subsequently result in a referral to the Director of Practice and a sanctions investigation.
In certain circumstances, IRS penalties can be mitigated or abated by a well prepared tax controversy attorney who can present your case in the correct manner, arguing that the penalty should not be asserted, or arguing that the taxpayer's tax reporting is based upon reasonable cause.A tax preparer penalty assessment may subsequently result in a referral to the Director of Practice and a sanctions investigation.
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TheBerliner
Dec 12, 2019
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