Tax Litigation

When a tax dispute cannot be resolved through administrative channels, litigation may become necessary. Pridgeon & Zoss, PLLC represents individuals and businesses in tax litigation before the U.S. Tax Court, federal district courts, and the Minnesota Tax Court. The firm brings decades of focused tax law experience to each case, working to protect clients' rights and pursue the most favorable outcome available under the law.

Tax litigation demands a thorough understanding of both procedural rules and substantive tax law. The firm handles cases involving income tax deficiencies, penalty assessments, trust fund recovery penalties, and other contested tax matters.

Audit Representation

An IRS or state audit notice can be unsettling, but having experienced counsel changes the dynamic. The firm represents clients through every stage of the audit process — from the initial document request to the final determination — ensuring that the government's inquiry stays within proper bounds and that the taxpayer's position is presented clearly and persuasively.

Audit representation includes preparing responses to information document requests, attending audit interviews on the client's behalf, negotiating with revenue agents, and, when necessary, challenging audit findings through the appeals process.

Tax Appeals

Not every audit outcome or tax determination is final. The IRS Office of Appeals and the Minnesota Department of Revenue each provide an independent forum for taxpayers to contest proposed adjustments without going to court. The firm prepares and presents appeals that identify errors in the government's analysis, raise applicable legal defenses, and advocate for a fair resolution.

Effective tax appeals require a command of the relevant statutes, regulations, and case law — and the ability to frame the dispute in terms that resonate with appeals officers. The firm's experience in this arena helps clients navigate the process with confidence.

Appealing Levy Actions

A levy — whether on wages, bank accounts, or other assets — is among the most aggressive collection tools the IRS and state revenue departments possess. Taxpayers have a limited window to challenge a levy and request a Collection Due Process (CDP) hearing. The firm acts quickly to file timely appeals, assert available defenses, and pursue alternatives such as installment agreements or offers in compromise that may make the levy unnecessary.

Prompt action is critical. Once a levy takes effect, recovering seized funds or property becomes far more difficult. The firm helps clients understand their rights and move decisively to protect their assets.

Related Services

Tax disputes often intersect with other tax problems. Clients facing an audit or appeal may also need help with: