Tax Controversy for Individuals

The Law Office of Pietro Canestrelli represents clients before federal and California state taxing authorities, with the objective of resolving disputes prior to litigation. At times, litigation is unavoidable or in the client’s best interest. We have substantial experience litigating tax cases across the country in state and federal courts, including the U.S. Tax Court, U.S. District Courts and U.S. Nineth Circuit Courts of Appeals. We regularly represent individuals in the following types of cases.

Assessments

Income Tax Disputes

Taxpayers can be the target of income audits by the IRS and the California Franchise Tax Board. The Law Office of Pietro Canestrelli represents the taxpayer from the initial audit through the appeals process and continuing into litigation in the U.S. Tax Court as well as the California Office of Tax Appeal. Attorney Pietro Canestrelli has represented hundreds of taxpayers before the U.S. Tax Court and hundreds more before the IRS Appeals division in income tax disputes and has reduced the amount owed by his clients by millions of dollars.
Taxpayers are often scared and confused by the income tax audit process. The taxpayer is at a disadvantage because of the asymmetry of knowledge and is frequently shocked by the audit results. Taxpayers would do well to bring in experienced representation as early as possible.

Have you received a notice of assessment? Contact our office today for guidance on your next steps. Call (951) 319-7674

Collections

Tax Collection Disputes

Sometimes taxpayers do not timely appeal their audits or the amount owed is undisputed. The Law Office of Pietro Canestrelli provides clients with options in these situations including Collection Due Process (CDP) request, Offer in Compromise request, and Innocent Spouse Relief.
The IRS, FTB have many programs to help taxpayers with tax liabilities they cannot pay at once. The Law Office of Pietro Canestrelli personally analyzes each client and determines which procedure and program will work best for them based on their current financial status, type of tax owed, and how old the tax liability is.

 

Non-Controversy Procedures

The Law Office of Pietro Canestrelli also specializes in providing taxpayers with expert tax guidance when there is no current controversy. These services include Tax Opinion Letters and Private Letter Ruling Requests.