When the IRS comes calling, the stakes are high. Whether you’re an individual taxpayer, a small business owner, or a corporation, a tax controversy can put your finances, reputation, and peace of mind at risk. That’s why it’s critical to know how to respond to the IRS, avoid costly mistakes, and when to contact a seasoned tax controversy attorney.

At The Law Office of Pietro Canestrelli, A.P.C., a leading tax law firm in Temecula and San Diego, we help clients across Southern California resolve disputes with the IRS. From audits to collection actions, we specialize in protecting your rights and finding the best path forward.

What Is a Tax Controversy?

A tax controversy is any dispute between a taxpayer and a tax authority, most commonly the Internal Revenue Service (IRS). These disagreements often revolve around unpaid taxes, audits, disallowed deductions, or reporting errors. A controversy can stem from:

• IRS audits (correspondence, office, or field audits)
• Unpaid or underreported taxes
• Late-filed or non-filed tax returns
• Incorrect classification of income or expenses
• Improper use of tax credits or deductions
• IRS collections, levies, or liens
• Criminal tax investigations

Step 1: Open and Read the IRS Notice Carefully

The first step is to remain calm and open the letter. Many clients initially panic and ignore IRS mail, but this only makes matters worse. Every IRS notice—whether it’s a CP2000, CP503, or a Notice of Deficiency—has a specific deadline and action item.

Don’t delay. Ignoring a letter could result in:

• Wage garnishments
• Bank account levies
• Federal tax liens
• Further enforcement actions

Pro tip: Save a copy of the envelope and all contents. Share them with your IRS representation lawyer for review.

Step 2: Identify the Nature of the Tax Dispute

IRS letters generally fall into a few categories. Understanding which kind of action is being taken against you will help determine the best response:

• Correspondence Audit: A request for documentation to support specific items on your return.
• Office/Field Audit: An in-person review of your books and records by an IRS agent.
• Collection Action: Involves attempts to recover unpaid tax debt via levies or liens.
• Notice of Deficiency (90-Day Letter): You must file a petition with U.S. Tax Court within 90 days or accept the liability.
• Criminal Investigation: If contacted by IRS Criminal Investigation, speak only through your tax lawyer.

Step 3: Gather Your Documentation

Next, you must collect all relevant tax documents to support your case. This includes:

• Federal and California state tax returns (past 3–7 years)
• 1099s, W-2s, and K-1s
• Bank and investment account records
• Business receipts and ledgers
• Mileage logs, charitable donation receipts
• Any prior IRS correspondence

Step 4: Consult With a Tax Controversy Attorney

Facing the IRS alone or relying solely on a CPA is a risky move. CPAs can prepare your taxes but don’t offer the same protections or legal authority as a licensed IRS tax lawyer.

At The Law Office of Pietro Canestrelli, our San Diego and Temecula tax attorneys offer:

• Attorney-client privilege protection
• Audit defense and representation before the IRS
• Litigation support in U.S. Tax Court
• Negotiation of Offer in Compromise (OIC) or Installment Agreements
• Help with penalty abatement and audit reconsideration
• Guidance for innocent spouse relief claims

Step 5: Respond to the IRS Promptly and Accurately

Every IRS notice includes a deadline. Responding late—or not at all—can lead to automatic assessments, seizure of assets, or referral to collections.

A complete response typically includes:

• A professional letter outlining your position
• Supporting documents
• Legal references or tax code citations
• A respectful and cooperative tone

Step 6: Explore All Resolution Options

Tax controversies rarely go away on their own. Depending on your situation, several resolution paths may be available:

• Audit Reconsideration
• Offer in Compromise (OIC)
• Installment Agreement
• Penalty Abatement
• Innocent Spouse Relief

Step 7: Monitor Your IRS Account

You can create an online IRS account to check your balances, notices, and payment history. For cases involving levies or liens, it’s wise to also monitor your credit reports to ensure no identity theft or tax fraud is involved.

Step 8: Avoid Future IRS Problems

Once your tax controversy is resolved, make compliance your priority by exploring our resources for unfiled taxes, back taxes owed, and managing tax debt.

Why Choose The Law Office of Pietro Canestrelli, A.P.C.?

We are not just any tax law firm in San Diego and Temecula—we are advocates who understand the fear and uncertainty that comes with an IRS notice. Clients choose us because:

• We specialize in IRS audit defense, tax debt settlement, and federal tax litigation
• We provide personalized strategies for businesses and individuals alike
• We help with complex issues like R&D tax credit audits, ERC disputes, and S-corp filings
• We serve clients across Riverside County, San Diego County, and the surrounding region

Contact a Tax Controversy Lawyer Today

Need help now? Contact our experienced team at The Law Office of Pietro Canestrelli. We offer comprehensive IRS representation services and legal strategies tailored to your needs.