We assist both individuals and businesses in disputing assessments, resolving collections issues, and defending criminal tax cases.
Civil Tax Controversies
Kulzer & DiPadova represents both individuals and businesses (both in state and out of state) in disputing potential tax assessments proposed by the Internal Revenue Service or the New Jersey Division of Taxation. Our involvement can begin at the earliest stages of an audit and if a resolution is not achieved at the audit level, we have extensive experience representing clients before the IRS Appeals Office as well as the New Jersey Division of Taxation. Ultimately, if an administrative settlement cannot be reached, the attorneys at Kulzer & DiPadova are very experienced in representing clients in litigation matters before the United States Tax Court as well as the New Jersey Tax Court.
Criminal Tax Controversies
Criminal tax is a unique type of criminal law. At Kulzer & DiPadova we specialize in handling criminal tax cases. Criminal tax cases can arise from a civil tax audit during which the IRS Auditor becomes concerned that false tax returns have been filed. In such situations the case will be referred to an IRS Special Agent to conduct a criminal investigation. Special Agents of the IRS work only with the Criminal Investigation Division (CI) and only get involved in criminal tax matters. Our attorneys are experienced in handling sensitive civil audits as well as cases that are referred to a Special Agent. Once a case if referred to a Special Agent it is extremely important to have quality and experienced legal representation. The best opportunity to have a case declined for criminal prosecution is at the Special Agent level. If the case goes beyond the Special Agent to the United States Attorney’s Office, 90% of such cases result in either a guilty plea or a conviction after trial.
Tax Collection Matters
Once a tax debt is assessed either by the IRS or the State of New Jersey, the applicable government agency expects payment of the tax to be made. Unfortunately, the taxpayer may not have sufficient funds to fully pay the debt. The attorneys at Kulzer & DiPadova have extensive dealing with such situations. We have been very successful in placing our clients in workable installment payment arrangements with both the IRS and the State of New Jersey. We have also been successful in compromising (reducing the debt) the tax liability in those situations where an installment arrangement will not result in full payment.
