An IRS audit letter creates immediate anxiety. The agency has vast resources, experienced examiners, and legal authority that few taxpayers understand how to navigate. Responding incorrectly to an audit, or failing to respond at all, can transform a manageable situation into a financial catastrophe with penalties, interest, and potential criminal exposure.
Texas businesses face additional complexity from state tax obligations. The Texas Comptroller audits sales tax, franchise tax, and other state levies with procedures and deadlines different from federal requirements. Taxpayers need attorneys who understand both systems and can coordinate defense strategies across jurisdictions when necessary.
What Tax Controversy Attorneys Handle
IRS Audit Defense
IRS audits range from correspondence audits handled entirely by mail to field examinations conducted at the taxpayer’s business. Tax controversy attorneys analyze the audit scope, identify potential issues, and develop response strategies. They handle document production, communicate with examiners, and protect taxpayers from providing information that could expand the audit or create additional liability. Proper representation often resolves audits at the examination level without need for appeals or litigation.
Appeals and Tax Court
When audits result in proposed adjustments taxpayers disagree with, appeals offer opportunity for resolution before litigation. Tax controversy attorneys present cases to the IRS Office of Appeals, negotiate settlements, and evaluate whether accepting proposed terms serves the client’s interests. When administrative resolution fails, they represent taxpayers in U.S. Tax Court, federal district courts, and the Court of Federal Claims.
Collection Defense
IRS collection actions including levies, liens, and wage garnishments require strategic response. Tax attorneys negotiate installment agreements, submit offers in compromise, and pursue penalty abatement when appropriate. They challenge improper collection actions and represent taxpayers facing Trust Fund Recovery Penalty assessments that create personal liability for business owners and officers.
Texas State Tax Matters
The Texas Comptroller of Public Accounts administers sales tax, franchise tax, and other state levies. Tax controversy attorneys defend against Comptroller audits, challenge proposed assessments through redetermination hearings, and litigate disputes before the State Office of Administrative Hearings when necessary. State procedures differ significantly from federal, requiring attorneys with specific Texas experience.
How to Choose a Tax Controversy Attorney
IRS experience. Tax controversy involves specialized procedures, deadlines, and strategies distinct from general tax practice. Choose attorneys who regularly handle IRS audits and understand examination techniques, appeal procedures, and litigation options.
Dual credentials. Many effective tax controversy attorneys also hold CPA licenses or have accounting backgrounds. This combination provides both legal advocacy skills and technical tax knowledge.
Former government experience. Attorneys who previously worked for the IRS or Department of Justice Tax Division understand how the government approaches cases and develops strategies.
State tax capability. Texas businesses often face both federal and state tax issues. Ensure your attorney can handle Texas Comptroller matters if state taxes are relevant to your situation.
Texas Tax Controversy Attorneys
Law Office of Stanton D. Goldberg
Location: Dallas, Texas
Website: https://www.stantongoldberg.com
Phone: (972) 960-2200
Attorney Stanton Goldberg is both a tax lawyer and certified public accountant, providing dual expertise in tax controversy matters. The firm represents clients facing IRS business and income tax audits, correspondence audits, and CP2000 notices. The practice handles Texas Comptroller sales tax audits and redetermination hearings, including litigation before the State Office of Administrative Hearings. The firm serves clients in Dallas, Collin, Rockwall, Tarrant, and Denton counties.
Practice Focus: IRS audit defense, IRS appeals and Tax Court representation, Texas Comptroller sales tax audits, collection defense, installment agreements, offers in compromise, penalty abatement
David Coffin PLLC
Location: Southlake, Texas (Dallas-Fort Worth area)
Website: https://www.davidcoffinlaw.com
Phone: (817) 251-7049
Attorney David Coffin brings over 30 years of tax law experience, including more than 11 years as a Trial Attorney for the Department of Justice Tax Division representing the IRS in federal and bankruptcy courts. This government experience provides insight into how the IRS approaches cases. Associate attorney Alejo Pacini holds a master’s degree in taxation with over 10 years of tax controversy experience. The firm serves clients throughout the Dallas-Fort Worth metroplex, across Texas, and nationwide.
Practice Focus: IRS audit defense, appeals representation, Tax Court litigation, offers in compromise, installment agreements, Trust Fund Recovery Penalty defense, employment tax resolution, payroll tax matters
Jackson Walker LLP
Location: Houston, Dallas, Austin, San Antonio (statewide)
Website: https://www.jw.com
Phone: (713) 752-4200
This Texas-based firm maintains a substantial tax controversy practice with attorneys holding LL.M. degrees in taxation and CPA licenses. The team includes recognized authorities on Texas franchise tax who recently represented a client in a landmark Texas Supreme Court case. The practice handles IRS examinations, appeals, and litigation as well as Texas Comptroller audit defense and state tax litigation. Attorneys assist CPAs with IRS audit support and provide legal analysis on discrete tax issues.
Practice Focus: IRS audits and examinations, federal tax litigation, Texas franchise tax disputes, Texas Comptroller audit defense, state and local tax controversy, private letter rulings, pre-controversy tax planning
Costs and Fees
Tax controversy fees depend on matter complexity and stage. Initial consultations to evaluate audit notices typically cost $200 to $500 or may be free. Simple correspondence audit representation might cost $1,500 to $5,000. Complex examination defense with substantial document review and multiple issues typically requires hourly billing at rates of $300 to $600 per hour. Appeals representation and Tax Court litigation involve higher costs reflecting the extensive preparation required. Some firms offer flat fee arrangements for defined matters like offers in compromise or installment agreement negotiations.
Frequently Asked Questions
Should I attend my IRS audit or have my attorney handle it?
In most cases, having your attorney represent you at the audit is advisable. Taxpayers who attend their own audits sometimes provide more information than legally required, answer questions in ways that create new issues, or make statements that expand the audit scope. Your attorney can manage the examination, produce only required documents, and prevent common taxpayer mistakes that increase liability.
What is an offer in compromise?
An offer in compromise allows taxpayers to settle IRS tax debt for less than the full amount owed. The IRS accepts offers when there’s doubt about collectibility, doubt about liability, or when collection would create economic hardship. Qualification requires demonstrating inability to pay the full amount through analysis of income, expenses, and asset equity. Many offers are rejected, so professional guidance improves approval chances.
How long does the IRS have to audit my return?
Generally, the IRS has three years from the filing date to audit a return. This extends to six years if gross income is underreported by more than 25%. There is no time limit for fraudulent returns or unfiled returns. Certain events can extend or suspend these periods. Understanding applicable limitations helps evaluate IRS audit notices and potential exposure.
This directory provides general information about tax controversy attorneys in Texas. It does not constitute legal advice or create an attorney-client relationship. Tax matters involve strict deadlines and significant financial consequences. Consult directly with a qualified tax attorney about your specific situation.
Last Updated: January 2026
Disclaimer: This directory is provided for informational purposes only and does not constitute legal advice, endorsement, or recommendation of any attorney or law firm. Information about attorneys and law firms was compiled from publicly available sources and may not be current or accurate. We make no representations or warranties about the qualifications, experience, or quality of any attorney listed. Fee estimates are approximations only and actual costs may vary significantly. Always verify attorney credentials with the State Bar of Texas, confirm current contact information, and conduct your own due diligence before hiring legal counsel. No attorney-client relationship is created by use of this directory.