IRS Controversy

  • An audit or investigation notice from the IRS is a moment everyone dreads...

    If you are contacted by the IRS, you need to have representation by knowledgeable and respected professionals who understand IRS practice and procedure.

    Paul Dougherty CPA, J.D., and Walter Pagano, CPA/CFF, CFE partners at EisnerAmper, have significant experience in IRS Controversy and have assisted clients and their counsel with:

    • Representation at IRS audits
    • Sensitive and complex matters
    • Tax controversy forensic accounting
    • Financial and accounting issues
    • Lien releases and discharges
    • Penalty abatements
    • Offers in compromise
    • Installment agreements
    • Representation at IRS appeals conferences
    • Representation re: employment tax audits
    • Representation re: trust fund recovery penalties

    Some examples of recent cases illustrate how Paul Dougherty, Walter Pagano and the IRS Controversy professionals at EisnerAmper can help you and your business when you have problems with the IRS:

    • An individual taxpayer was assessed $2.5 million in income tax as a result of an IRS Examination. Met with IRS Appeals Office in Florida and settled the case for $80,000.
    • An electrical contractor owed $1 million in payroll taxes, penalty and interest. The IRS Collection Division agreed to abate $350,000 in penalty and accepted $650,000 as payment in full.
    • An individual taxpayer was assessed $900,000 in Trust Fund Recovery Penalty. Filed an Offer in Compromise and settled the case for $13,000.
    • A manufacturing company was unable to refinance their existing bank debt because of IRS liens. We were able to obtain a subordination agreement from the IRS that allowed them to refinance their debt.
    • The IRS obtained from a taxpayer an extension of time to collect tax. We were able to get District Counsel to withdraw the extension of time because it was obtained under duress, thereby not collecting any money from the taxpayer.
    • Provided expert testimony for the defense in an income tax Spies evasion and failure to file case that resulted in a directed verdict of acquittal for the defendant.
    • Retained by counsel as a Kovel accountant in numerous federal and state examinations, investigations and prosecutions.
    • Engaged to represent a closely-held company in a tax dispute with IRS Examination and Appeals.
    • In connection with a federal prosecution for money laundering, structuring and income tax evasion, acted as a defense expert consultant during trial to assess the testimony of government agents.
    • Provided expert testimony for the State of New Jersey regarding IRS practice and procedure in connection with a pension audit dispute that resulted in the trier of fact granting the state’s motion.

    Paul Dougherty has close to 30 years experience in public accounting. He earned his Juris Doctor Degree from New York Law School and has passed both the New York and New Jersey State Bar examinations. He has a Master of Science degree in Taxation.

    Walter Pagano, a former IRS revenue agent and District Conferee, brings more than 35 years of IRS and public accounting experience in civil and criminal tax controversy including IRS practice and procedure, forensic accounting, and litigation consulting.  He has successfully represented clients in sensitive and complex tax audits, investigations and appeals.  Walter is a member of the IRS Advisory Council.

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EisnerAmper is an independent member of Allinial Global.
EisnerAmper is an independent member of EisnerAmper Global.