Miami, FL: (305) 400-4260

Ft. Lauderdale, FL: (954) 462-1200

Premier White Collar Litigation Boutique

Tax Controversies & Compliance

Marcus Neiman & Rashbaum LLP has vast experience litigating tax controversies. Tax controversies can be sensitive and difficult to navigate because similar conduct may be treated civilly in some cases and criminally in others. Knowing how to deal with the Internal Revenue Service is critical for successful resolution of these kinds of matters. MNR helps taxpayers and tax professionals navigate through the issues that may arise in dealing with tax controversies, including:
• Representing taxpayers in civil audits, including deal with Revenue Agents and Officers, Appeals Officers, and IRS attorneys
• Representing taxpayers in “eggshell” or sensitive audits
• IRS penalty mitigation including litigation relating to failure to file Foreign Bank Account Reports (FBARs) and fraud
• Dealing with sensitive issue tax problems and examinations such as unreported or under-reported income, alleged tax shelters, and undeclared foreign financial accounts and assets
• Representing taxpayers in criminal tax and related investigations (administrative and grand jury), including representations before IRS Special Agents, Department of Justice Tax Division, and before federal prosecutors
• Handling all aspects of criminal trials, from pre-indictment dispositions to indictment through trial and appeals
• Defending accountants and other return preparers in investigations for aiding and assisting in the preparation of allegedly false tax returns, conspiracy, and related. charges

Marcus Neiman & Rashbaum LLP also assists American taxpayers, foreign advisors, and foreign financial institutions with offshore tax compliance issues. The Justice Department and the Internal Revenue Service have actively been enforcing strict laws which require the disclosure of assets and bank accounts held outside of the United States. Failure to comply with the law can result in fines, penalties, and sometimes criminal prosecution. Always with a practical approach in mind, we try to help clients find solutions that will reduce the possibility of criminal prosecution and minimize financial penalties.

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Recent Cases

  • Successful representation of a Taxpayer accused of filing fraudulent tax returns. After trial, the Tax Court found that the IRS did not prove taxpayers intended to evade tax and therefore the IRS was banned from assessing $2 million in tax and penalties.
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