Disagree with What the IRS Says You Owe?
I challenge it with facts, law, and experience.

With 25+ years of legal and tax experience as a tax litigation attorney, I help U.S. taxpayers nationwide and abroad prepare for litigation, protect their rights, and pursue resolution through proven legal strategy.

Request Your Tax Litigation Case Review

When IRS disputes don’t settle, this is what comes next

Most people don’t plan to end up in tax litigation. But it happens the moment the IRS refuses to back down, and you don’t take legal action to stop it.
Here’s what pushes tax disputes into litigation
  • IRS audits that lead to inflated assessments, you know, are wrong
  • Disallowed deductions or credits that you have proof for, but the IRS won’t accept
  • Appeals that are denied or ignored, leaving you no other path but court
  • Notices of deficiency (90-day letters) that force you to file a Tax Court petition
  • Ongoing penalties and interest that grow while your side of the story is left unheard
If you believe the IRS made a mistake and they won’t fix it, you’re not just dealing with a tax issue anymore; you’re in a legal dispute.
That’s where Verni Tax Law’s tax litigation attorney steps in with litigation counsel built to protect your rights and challenge the IRS head-on.

Our Civil Tax Litigation Practice Areas

IRS Audit Defense & Tax Assessment Challenges

If the IRS is auditing you or you’ve received a notice of deficiency, your finances could be at risk. I represent taxpayers through every stage, reviewing documents, attending meetings, and challenging unfair assessments to protect your rights.
I help you:
  • Respond strategically to IRS audit notices
  • Challenge inflated tax liabilities or errors
  • Conduct administrative appeals with confidence

Corporate & Business Tax Litigation

Tax disputes can seriously disrupt operations and lead to heavy penalties. I help corporations, partnerships, and small businesses navigate complex federal and state issues, from payroll tax problems to classification disputes and multi-state audits.

As a tax dispute lawyer, I provide business tax litigation services that include:

  • Payroll tax defense and employment classification disputes
  • State income tax and sales tax controversies
  • Defense against civil penalties and interest assessments

Individual Tax Litigation & Criminal Tax Defense

If the IRS targets you for unpaid taxes, fraud, or investigation, immediate legal help is crucial. I represent individuals in tax court, handle collection disputes, and defend against civil fraud claims.
I represent individuals in:
  • Civil tax fraud and penalty abatement cases
  • Tax court representation and appeals
  • Collection defense and Offers in Compromise (OIC)

Not every tax dispute ends up in court, but the cost of being unprepared is always real.

If you're facing IRS pressure, a notice of audit, or unresolved back taxes, a strategic review can protect your finances, your rights, and your peace of mind.
Book a Confidential Legal Review Today

Tax Litigation Process Explained

Our IRS Audit Representation Process

Step 1

Pre-Litigation Assessment

I start by reviewing your situation, identifying risks, and outlining possible paths forward. This initial step helps us position your case for the best possible outcome, whether that means resolution or litigation.
Step 2

Administrative Appeals & Negotiations

In many cases, such as disputed audit results, proposed penalties, or unexpected tax assessments, I can resolve the issue without going to court. I explore available administrative channels and pursue the most effective path based on your circumstances.
Step 3

Litigation & Court Proceedings

If the matter requires formal litigation, I'm fully prepared to represent you in court. From filings to final resolution, I manage every step with a focus on protecting your rights.

Don’t Guess What Comes Next; Know It.

Understanding the process is your first layer of protection. Learn how to prepare for audits, appeals, and litigation so you can make informed decisions before the IRS makes the next move.
Book a Tax Litigation Assessment

Why Taxpayers in Disputes Trust Verni Tax Law?

25+ Years of IRS Audit Experience

I don’t just understand tax law; I know how to apply it in courtrooms and negotiation rooms. From audit disputes to Tax Court petitions, I handled litigation at every level.

Dual-Credentialed: Attorney, CPA, and MBA

With an Attorney, CPA, and MBA behind your case, you get strategic legal representation with a complete view of the financial, procedural, and legal landscape.

Audit-Specific Focus

Skilled in reducing audit scope, identifying risk triggers through transcript analysis, and negotiating directly with IRS agents.

Litigation Strategy, Not Just Representation

I evaluate your case, identify risks, and challenge unfair IRS positions with clear, legally sound strategy, whether through appeals or full litigation.

National Reach with Local Insight

From my offices in Princeton, NJ and Fort Lauderdale, FL, I represent taxpayers in all 50 states and those living abroad who are still subject to IRS enforcement.

Designed for High-Stakes IRS Disputes

This isn’t tax prep. I take on cases where your rights, finances, and future are at risk and build a litigation response that reflects that seriousness.

Our Approach Is Strategically Built Around Your Case

No two tax disputes are alike, but each one demands a focused legal strategy. At Verni Tax Law, I don’t just represent clients; I evaluate, plan, and act with precision. Every step I take is tailored to the complexity and urgency of your situation.
From my offices in Princeton and Fort Lauderdale, I continue to support individuals and businesses across the U.S., and even clients living overseas with U.S. tax obligations. One conversation, no matter where you're located, can shift the direction of your entire tax matter.

Fill out the form below or book a call with me to get started.

When IRS disputes don’t settle, this is what comes next

Most people don’t plan to end up in tax litigation. But it happens the moment the IRS refuses to back down, and you don’t take legal action to stop it.
Here’s what pushes tax disputes into litigation
  • IRS audits that lead to inflated assessments, you know, are wrong
  • Disallowed deductions or credits that you have proof for, but the IRS won’t accept
  • Appeals that are denied or ignored, leaving you no other path but court
  • Notices of deficiency (90-day letters) that force you to file a Tax Court petition
  • Ongoing penalties and interest that grow while your side of the story is left unheard
If you believe the IRS made a mistake and they won’t fix it, you’re not just dealing with a tax issue anymore; you’re in a legal dispute.
That’s where Verni Tax Law’s tax litigation attorney steps in with litigation counsel built to protect your rights and challenge the IRS head-on.

Our Civil Tax Litigation Practice Areas

IRS Audit Defense & Tax Assessment Challenges

If the IRS is auditing you or you’ve received a notice of deficiency, your finances could be at risk. I represent taxpayers through every stage, reviewing documents, attending meetings, and challenging unfair assessments to protect your rights.
I help you:
  • Respond strategically to IRS audit notices
  • Challenge inflated tax liabilities or errors
  • Conduct administrative appeals with confidence

Corporate & Business Tax Litigation

Tax disputes can seriously disrupt operations and lead to heavy penalties. I help corporations, partnerships, and small businesses navigate complex federal and state issues, from payroll tax problems to classification disputes and multi-state audits.

As a tax dispute lawyer, I provide business tax litigation services that include:

  • Payroll tax defense and employment classification disputes
  • State income tax and sales tax controversies
  • Defense against civil penalties and interest assessments

Individual Tax Litigation & Criminal Tax Defense

If the IRS targets you for unpaid taxes, fraud, or investigation, immediate legal help is crucial. I represent individuals in tax court, handle collection disputes, and defend against civil fraud claims.
I represent individuals in:
  • Civil tax fraud and penalty abatement cases
  • Tax court representation and appeals
  • Collection defense and Offers in Compromise (OIC)

Not every tax dispute ends up in court, but the cost of being unprepared is always real.

If you're facing IRS pressure, a notice of audit, or unresolved back taxes, a strategic review can protect your finances, your rights, and your peace of mind.
Book a Confidential Legal Review Today

Tax Litigation Process Explained

Our IRS Audit Representation Process

Step 1

Pre-Litigation Assessment

I start by reviewing your situation, identifying risks, and outlining possible paths forward. This initial step helps us position your case for the best possible outcome, whether that means resolution or litigation.
Step 2

Administrative Appeals & Negotiations

In many cases, such as disputed audit results, proposed penalties, or unexpected tax assessments, I can resolve the issue without going to court. I explore available administrative channels and pursue the most effective path based on your circumstances.
Step 3

Litigation & Court Proceedings

If the matter requires formal litigation, I'm fully prepared to represent you in court. From filings to final resolution, I manage every step with a focus on protecting your rights.

Don’t Guess What Comes Next; Know It.

Understanding the process is your first layer of protection. Learn how to prepare for audits, appeals, and litigation so you can make informed decisions before the IRS makes the next move.
Book a Tax Litigation Assessment

Why Taxpayers in Disputes Trust Verni Tax Law?

25+ Years of IRS Audit Experience

I don’t just understand tax law; I know how to apply it in courtrooms and negotiation rooms. From audit disputes to Tax Court petitions, I handled litigation at every level.

Dual-Credentialed: Attorney, CPA, and MBA

With an Attorney, CPA, and MBA behind your case, you get strategic legal representation with a complete view of the financial, procedural, and legal landscape.

Audit-Specific Focus

Skilled in reducing audit scope, identifying risk triggers through transcript analysis, and negotiating directly with IRS agents.

Litigation Strategy, Not Just Representation

I evaluate your case, identify risks, and challenge unfair IRS positions with clear, legally sound strategy, whether through appeals or full litigation.

National Reach with Local Insight

From my offices in Princeton, NJ and Fort Lauderdale, FL, I represent taxpayers in all 50 states and those living abroad who are still subject to IRS enforcement.

Designed for High-Stakes IRS Disputes

This isn’t tax prep. I take on cases where your rights, finances, and future are at risk and build a litigation response that reflects that seriousness.

Our Approach Is Strategically Built Around Your Case

No two tax disputes are alike, but each one demands a focused legal strategy. At Verni Tax Law, I don’t just represent clients; I evaluate, plan, and act with precision. Every step I take is tailored to the complexity and urgency of your situation.
From my offices in Princeton and Fort Lauderdale, I continue to support individuals and businesses across the U.S., and even clients living overseas with U.S. tax obligations. One conversation, no matter where you're located, can shift the direction of your entire tax matter.

Real People. Real Disputes. Resolved With Strategy.

Anthony was creative in helping me resolve some past issues in a way that they never became a problem so that is greatly appreciated and I feel confident I can now enjoy my retirement with peace of mind. Thanks for that.

Ken B.

Cebu City, Philippines

I came to Anthony Verni with FBAR issues. I was not sure what to expect and felt that I was going to be put in a difficult position financially as well as legally. My fears were unfounded and I was very satisfied with his professionalism and the outcome of my case.

Douglas R.

Osaka, Japan

Anthony’s help with Swift & Secure Systems Inc., CheckWare Workstations LLC and my personal taxes have been of great value. Since moving to Florida (and my Connecticut Accountant retiring) I have tried various other methods of keeping the accounting and taxes under control.

Phil Y

President, Swift & Secure Systems Inc., Boynton Beach, FL

I would like to thank Anthony N. Verni.   Mr. Verni has successfully represented us before the Internal Revenue Service. We had foreign bank accounts that we inadvertently didn’t report and we were subject to steep penalties. As a result his efforts, the FBAR penalties were waived by the IRS.
Thank You

Yassin and Eva, B.

Farmington Hills, Michigan

Have questions or need guidance?

I’m always available by phone, email, or Skype whatever’s easiest for you.

Take the first step and let me help fix the root of your tax problems.

Frequently Asked
Questions

A tax litigation attorney represents taxpayers when the IRS takes a position they refuse to back down from. This includes defending you in Tax Court or District Court, challenging IRS determinations, filing petitions, handling pre-trial negotiations, and protecting your legal rights throughout the dispute process.

If the IRS has made a decision you don’t agree with and won’t correct it, now is the time to hire litigation counsel. This includes after an audit, a denied appeal, or if you’ve received a Notice of Deficiency or a formal demand that may lead to court.

When audits turn aggressive or result in inaccurate assessments, a tax litigation attorney steps in to challenge the outcome. I analyze the IRS’s position, represent you in meetings, handle appeals, and prepare your case for court if resolution isn’t possible through standard channels.

Businesses frequently face disputes involving payroll taxes, misclassified employees, overstated deductions, sales and use tax issues, and penalties for late filings or payments. These disputes often involve large dollar amounts and can quickly escalate into legal action if not handled properly.

Some disputes resolve in a few months through pre-litigation settlement or appeals. Others may take over a year, especially if they proceed to trial. The timeline depends on the complexity of the case, court scheduling, and whether the IRS is willing to negotiate.

Yes. A qualified tax attorney can pursue settlement options with the IRS at multiple stages, including during audit reconsideration, administrative appeals, or litigation. This could involve reducing the amount owed, eliminating penalties, or reaching a structured resolution.

Costs vary depending on the stage and complexity of your case, whether it’s resolved in appeals or proceeds to court. During your initial case review, I provide a clear explanation of potential legal fees and litigation costs, so there are no surprises.

I manage every stage of preparation, from filing the Tax Court petition to reviewing your records, identifying key legal arguments, and representing you during proceedings. You’ll know what to expect, what to bring, and how I’ll present your case.

A tax litigation attorney represents taxpayers when the IRS takes a position they refuse to back down from. This includes defending you in Tax Court or District Court, challenging IRS determinations, filing petitions, handling pre-trial negotiations, and protecting your legal rights throughout the dispute process.

If the IRS has made a decision you don’t agree with and won’t correct it, now is the time to hire litigation counsel. This includes after an audit, a denied appeal, or if you’ve received a Notice of Deficiency or a formal demand that may lead to court.

When audits turn aggressive or result in inaccurate assessments, a tax litigation attorney steps in to challenge the outcome. I analyze the IRS’s position, represent you in meetings, handle appeals, and prepare your case for court if resolution isn’t possible through standard channels.

Yes, as a US taxpayer, you generally must report financial accounts that your foreign businesses maintain if you have signature authority or financial interest in those accounts and if the aggregate value exceeds $10,000 at any point during the year. I can help by:

  • Conducting a comprehensive review of your global business structure
  • Identifying all reportable accounts across your multiple businesses
  • Preparing the necessary FBAR filings
  • Addressing any past non-compliance through appropriate disclosure programs
  • Creating a sustainable compliance strategy for future years

I offer flexible consultation scheduling to accommodate clients worldwide. Initial consultations typically last 45-60 minutes and can be conducted by phone, secure video conference, or in person at my Princeton or Fort Lauderdale offices. 

To schedule, you can call directly at (561) 531-8809 or use the secure contact form on my website. All consultations are confidential and protected by attorney-client privilege.

These complex cases require a multi-faceted approach. I’ll first assess whether you qualify for the Streamlined Filing Procedures or need to pursue other disclosure options. Then I’ll develop a comprehensive strategy that addresses both issues simultaneously, ensuring all filings are consistent. 

My experience with the Offshore Voluntary Disclosure Program since 2009 provides valuable insight into how the IRS approaches these cases, allowing me to anticipate challenges and develop effective responses that minimize penalties while bringing you into full compliance.

My approach to tax dispute resolution is distinguished by three key elements:

  1. Comprehensive analysis: I conduct an exhaustive review of your financial documentation and tax history before developing any strategy, often revealing options and defenses that might otherwise be overlooked.
  2. Strategic negotiation: Rather than taking an adversarial stance with tax authorities, I focus on collaborative problem-solving when possible, which has repeatedly resulted in favorable settlements.
  3. Direct attorney involvement: I personally handle every aspect of your representation, ensuring that the expertise you’re paying for is actually applied to your case at every stage of the process.