Convicer & Percy, LLP, has extensive experience in civil tax controversies and litigating tax matters. We regularly represent clients before the Internal Revenue Service as well as before the Massachusetts and Connecticut Departments of Revenue. Attorney Convicer and Attorney Percy both served with the IRS Office of Chief Counsel before entering private practice. The firm responds aggressively, yet realistically, to any tax challenge raised by a government taxing authority. As a result of the firm’s many years of practice in this area, we have a unique and unusually deep understanding of government agencies’ practices and procedures.
The firm regularly represents clients who seek to challenge a proposed civil tax liability, who need to work out an arrangement to resolve a past tax debt, or who failed to file tax returns. The firm has negotiated hundreds of payment arrangements with the Internal Revenue Service, Massachusetts Department of Revenue and Connecticut Department of Revenue Services. We have represented taxpayers through voluntary disclosures, thereby both avoiding criminal prosecution and limiting civil penalties on behalf of clients.
Our objective in all matters is to resolve issues quickly, efficiently, and successfully. Though we always seek ways to resolve tax controversies prior to litigation, we are prepared to take a matter to trial when this is to our client’s advantage. Our experience encompasses all facets of negotiation with tax authorities, and all phases of tax litigation, including responding to audits, summonses and subpoenas, preparing administrative protests and petitions, discovery, depositions, dispositive motions, trials, and appeals. We also represent clients faced with summonses or subpoenas demanding documents or testimony in connection with a tax matter.
We handle federal tax matters of corporations, partnerships, and individuals. We routinely represent taxpayers before the Examination Division, Appeals Office, and Collection Division of the Internal Revenue Service. We try cases in the United States Tax Court and the United States District Courts. We regularly are involved with client offers in compromise, installment agreements, and innocent spouse relief applications, as well as handling all manner of payroll tax issues with the objective of minimizing personal liability for such payroll taxes. In addition to income and payroll taxes, we are experienced in handling estate and gift tax matters, both audit examinations of returns as well as resolving valuation and payment issues.
We have also assisted clients with Bank Secrecy Act issues, including 8300 exams, where the taxpayer’s reporting compliance was brought into question and successfully resolved the issue with the special BSA examiners.
State Tax Issues
Along with our federal tax practice, we represents business and individual clients in connection with state tax issues including sales, payroll, and withholding income taxes. We have extensive experience in handling sales tax examinations and Business Employment Tax Audit (“BETA”) Unit withholding tax examinations, representing clients at the administrative appeal level, and litigating cases in state court, including several cases before the Connecticut Supreme Court. We also represent taxpayers in domicile and residency cases.