Civil Litigation
The ultimate goal in every case is to reach a favorable outcome for the client in as efficient a manner as possible. The best way of meeting this goal is to settle cases prior to litigation, but this is not always a viable option. If litigation is required, we are highly skilled litigators prepared to represent you in federal court.
We will litigate your case in one of four courts:

  • U.S. Tax Court: This is where the majority of tax cases are heard. Judges in this court have extensive knowledge of U.S. tax law. The biggest advantage to requesting a hearing in the U.S. Tax Court is that taxpayers are not required to pay their assessment prior to the hearing as they are in federal district court.
  • U.S. District Court: In order to be granted a hearing in this court, taxpayers must have exhausted all of the administrative options for resolving their case and must have paid the assessed tax before filing a suit for a refund. Despite this drawbacks, this forum can be advantageous since it is the only court that gives you the option of a jury trial.
  • U.S. Bankruptcy Court: If you or your business has filed for bankruptcy, this court may decide whether IRS tax assessments or liens are valid. It can also determine whether or not your tax liabilities may be discharged as part of your bankruptcy filing.
  • U.S. Court of Federal Claims: Based in Washington, D.C., this court may be the most favorable if you have already paid the disputed tax and wish to sue for a refund.

Whether your tax issue is resolved through negotiation or before a judge, Glen Frost is committed to protecting your rights as a taxpayer and achieving the best possible outcome in your case.

Criminal Litigation
Can you tell us if you are currently under criminal investigation by the IRS? Surprisingly, you may not even know it. Here are some warning signs that your audit has turned into a criminal investigation:

  • Revenue Agents who have been auditing your tax return disappear
  • Revenue Officers who were once aggressive stop calling
  • You or someone else associated with you is contacted by an IRS Special Agent

Criminal cases usually begin with case referrals to the Criminal Investigations Division from auditors who see clear indicators of fraud. You still retain your rights as a taxpayer when under criminal investigation, and are strongly advised to contact a tax attorney if you are or believe you could be under criminal investigation. If contacted by an IRS Special Agent, you have the right to tell him/her that you are currently seeking legal counsel and will not answer their questions without your attorney present. The criminal investigation statistics are proof enough how necessary it is to have an experienced criminal tax litigation lawyer under these circumstances.