Tax Litigation

When tax disputes cannot be resolved through negotiation or administrative channels, litigation may be necessary. Philip Falco represents taxpayers in tax disputes at both the federal and state level, bringing the dual perspective of an Attorney and CPA to every case.

Federal Tax Litigation

• United States Tax Court — petition the Tax Court to challenge IRS determinations before paying the disputed tax
• IRS Appeals — represent taxpayers in the IRS Appeals Office for pre-litigation resolution
• Collection Due Process hearings — challenge IRS collection actions including levies and liens
• Innocent Spouse Relief — represent spouses seeking relief from joint tax liability

State Tax Litigation

• Colorado Department of Revenue disputes — challenge state tax assessments and audit findings
• Sales tax disputes — represent businesses in sales and use tax controversies
• Colorado Department of Labor — employment tax disputes

The Attorney Advantage in Tax Litigation

Only attorneys can represent taxpayers in Tax Court. CPAs and enrolled agents cannot appear before the Tax Court in most cases. As a dual-licensed Attorney and CPA, Philip Falco provides both legal representation and the financial expertise necessary to build a strong case.

Attorney-client privilege protects all communications during the litigation process, ensuring your strategy and disclosures remain confidential.

Call (303) 626-7000 to discuss your tax dispute.