Tax Controversy and Tax Disputes

Whiteman Osterman & Hanna represents businesses and individuals in federal and New York State tax controversies, including IRS and New York State tax audits, assessments, appeals, collection matters and litigation.

Tax Controversy

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Overview

A tax dispute can begin with an audit notice or information request and develop into a significant financial and legal problem. Our tax attorneys help clients understand their rights and obligations, respond to taxing authorities, evaluate potential liabilities, pursue administrative remedies and, when necessary, litigate tax disputes.

IRS Tax Controversies

Our attorneys represent taxpayers in matters involving the Internal Revenue Service, including:

  • IRS audits and examinations
  • Proposed tax assessments
  • Federal income tax disputes
  • Employment tax matters
  • Refund claims
  • Penalties and interest
  • Collection matters
  • Appeals of IRS determinations
  • United States Tax Court proceedings
  • Federal tax litigation

New York State Tax Controversies

We represent taxpayers in disputes with the New York State Department of Taxation and Finance and before the New York State Division of Tax Appeals and Tax Appeals Tribunal.

Our experience includes:

  • New York State income tax audits
  • Sales and use tax audits and assessments
  • New York State residency and domicile disputes
  • Tax assessments
  • Refund claims
  • Penalties and interest
  • Tax collection matters
  • Administrative protests and appeals
  • Proceedings before the Division of Tax Appeals
  • Proceedings before the Tax Appeals Tribunal
  • New York State tax litigation
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Tax Audits and Examinations

Receiving an audit notice does not necessarily mean that a taxpayer owes additional tax. An examination may involve questions regarding income, deductions, sales tax, residency, business activities, employment taxes or other issues.

Our attorneys help clients evaluate the scope of an examination, respond to information requests, communicate with taxing authorities and develop a strategy for resolving the matter.

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Tax Assessments and Appeals

When a taxing authority proposes or issues an assessment, taxpayers may have administrative rights and deadlines that must be evaluated promptly. We advise clients regarding protest and appeal procedures, settlement opportunities and litigation options.

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New York Residency and Domicile Disputes

New York residency examinations can involve substantial financial exposure and complex factual questions concerning domicile, statutory residency, days present in New York and connections to the state.

Our attorneys represent taxpayers in New York residency disputes and advise clients regarding both examination strategy and administrative appeals.

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Sales and Use Tax Controversies

New York sales and use tax matters can result in significant assessments, particularly for businesses with complex operations or questions regarding the taxability of transactions.

We represent businesses and owners in sales and use tax audits, assessments, administrative proceedings and appeals.

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Federal and New York State Tax Dispute Representation

Tax controversies frequently involve both substantive tax questions and procedural requirements. Our attorneys combine substantive federal and New York tax knowledge with experience representing taxpayers before administrative agencies and courts.

We also work with the Firm’s business, litigation, real estate, trusts and estates, and other practice groups when a tax controversy involves broader business or legal issues.

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Meet Our Attorneys

Scott D. Shimick

Scott D. Shimick

Partner

Meet Our Attorneys

Partners

Scott D. Shimick

Scott D. Shimick

Partner

Explore Related Areas

Legal matters often involve interconnected issues that span multiple areas of the law. Understanding these relationships is essential to navigating complex challenges and making informed decisions.

Our attorneys work collaboratively across different industries to provide coordinated guidance that reflects the broader legal and operational landscape. This approach helps ensure consistency, efficiency, and clarity at every stage.

Explore related practice areas and industries to learn how our team delivers comprehensive support designed to adapt to a wide range of needs and circumstances.