IRS Tax Audit


We can support you through the challenges of a tax audit, controversy, or IRS calls and correspondence. Your relationship with the IRS and other taxing agencies needs to be professionally managed. This includes assistance with delivering the information required to complete any inquiry or audit; or a solid defense of your tax position.


When the IRS audits your tax return, and tries to collect taxes by disallowing deductions you can often argue the facts or the interpretation of the tax law.  But, when you fail to include a required tax form with your US income tax return, there is little left to argue about. We strive to provide strategically sound advice when dealing with tax issues.



Tax Disputes Resolution Services

  • Managing relationships with the tax authorities

  • Tax audit and controversy support

  • Tax examinations

  • Defending your tax position

  • Appeal conferences or hearings

  • Alternate dispute resolution

  • Domestic and international compliance issues

  • Special audit review for art work and appraised valued         declarations

  • IRS payment plan agreement

  • Closure notices

  • Tax underpayments

IRS Audit Team


The IRS has a special unit dedicated to investigating potential criminal violations of the Internal Revenue Code and related financial crimes including money laundering, currency crimes, antitrust violations and Bank Secrecy Act violations. This unit, the IRS Criminal Investigation Division (“CI”) is composed of Special Agents who are expertly trained financial investigators. CI Special Agents employ law enforcement techniques such as wiretaps, search warrants and undercover operations. These agents aggressively conduct exhaustive, in-depth investigations into individuals and businesses to uncover tax and financial crimes, including:


  • General Tax Fraud

  • Return Preparer Fraud

  • Questionable Refunds

  • Abusive use Trusts

  • Frivolous Filer/Non-Filer

  • Employment Tax Fraud

  • Voluntary Disclosures

  • Undisclosed Offshore Accounts

  • Excise Tax Fraud


CI’s conviction rate is one of the highest in federal law enforcement.  Not only do the courts hand down substantial prison sentences in such cases, but those convicted must often pay fines civil penalties and interest in addition to any back taxes owed. 


The early involvement of experienced legal counsel can help lead to a successful result.  We will help you to cooperate with investigators to the extent required by law, while fully asserting any available defenses you may have, including your Constitutional privilege against self-incrimination. 


If you are the target of a Government investigation into alleged criminal misconduct, you will want a legal tax representative by your side as part of your team.


IRS Criminal Tax Investigations - Criminal Tax Defense

We can help you understnd the process of a criminal tax investigation.  We can represent you before the IRS, in voluntary disclosures, deferred prosecution agreements, plea agreements and settlement negotiations. We can help you help you with:


  • Tax Fraud

  • Tax Evasion

  • Egg Shell Audits   

  • Parallel Proceedings

  • Unfiled Tax Returns

  • Tax Shelter Promoter Investigations

  • Employer (Payroll) Tax Investigations

Rulings from Tax Authorities


How can you be sure that your proposed transaction will be tax efficient?


Although the process takes time, the IRS is amenable in certain situations to issuing rulings that are favorable. It is important also to know when pursuing a ruling is not worthwhile.


IRS Audits & Appeals

Audit Representation

Are you facing an audit by the Internal Revenue Service and are concerned about fair treatment?


Understanding the IRS interpretation of the relevant tax laws and regulations, any audit policies being applied, and how to present your facts persuasively, all combine to affect audit results significantly. 


IRS Administrative Appeals

Despite the best efforts, tax issues cannot always be resolved at the audit level.


In these circumstances, we often recommend the IRS Office of Appeals (“IRS Appeals”) review the matter. IRS Appeals is a neutral body within the IRS that is dedicated to resolving disputes between taxpayers and the IRS without the need for litigation. Many cases are resolved by utilizing the IRS Appeals process and preparing Offers in Compromise on behalf of our clients. 


We can assist in representing individual taxpayers, businesses, trusts, partnerships and other entities, which are under civil audit by the Internal Revenue Service.


We work directly on our clients’ behalf to resolve tax issues and close audits as quickly as possible, and with the least amount of taxes, penalties and interest due.


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Office: (305) 600-5924


South Florida Offices:

Law Offices of Jason R. Kovan

4440 PGA Boulevard, Suite 600

Palm Beach Gardens, FL 33410