“An IRS audit is an official investigation that may be the first step leading to a criminal conviction for tax violations. United States v. Peters, 153 F.3d 445, 447 (7th Cir. 1998). The audit places a taxpayer on notice that the government is looking into the accuracy and propriety of his or her tax returns.”
– United States v. Yip, 9th Cir. 2010
Agostino & Associates has represented taxpayers in connection with federal, state, and local civil and criminal tax controversies for over 25 years.
Agostino & Associates represents taxpayers in civil litigation against the Internal Revenue Service and state taxing authorities. The firm has been recognized by Chambers & Partners USA, the American Bar Association, the New Jersey Bar Association, and the New York County Lawyer’s Association. Our attorneys appear regularly before the United States Tax Court.
Agostino & Associates
Monthly Journal of Tax Controversy
July 2024 Agostino Journal
II. Overview of the CAP Process
A. Appealable Actions Under CAP
1. Notice of Federal Tax Lien (NFTL)–filed or proposed
2. Levy taken or proposed
3. Seizure of property
4. Rejection, modification or termination of an installment agreement
FILING THE IRS FORM 9423–COLLECTION APPEAL
REQUEST–BEST PRACTICES by Frank Agostino, Esq.,
Yiwei Chen, J.D., and Shan Kadkoy, Esq.
FORM 9423 ANALYSIS
COLLECTION APPEALS PROGRAM (CAP) APPEAL
COVER LETTER
FILING THE IRS FORM
9423–COLLECTION
APPEAL REQUEST–
BEST PRACTICES
September 2023 Agostino Journal
Best Practices for Contesting IRS Form Payee States and Third-Party Information Reports
by Frank Agostino, Esq. and Yiwei Chen
Exhibit A- Sample Letter to Issuer Requesting CORRECTED Form
Exhibit B- Sample Letter To The IRS Reposting an Incorrect Payee Statement
Exhibit C- Sample Disclosure Statement
Exhibit D- Sample Response to IRS Notices
Written Examination Information
2023 Tax Controversy Seminar Series
2023 Practice Exam
Joining the Google Group
Interpreting and Responding to IRS Notices, and How to Use the IRS Online Services 22
May 2023 Agostino Journal
The Taxation of Performing Artists, Showbiz, and the Entertainment Industry
by Frank Agostino, Esq., Young H. Kim. Esq., and
Byung Hyuk (Billy) Min, Esq.
Challenging Form K-1, Steps to Take When Inconsistencies Arise
by Frank Agostino, Esq., Matthew Rego, Esq., and Giorgi Tsitsuashvili, LLM