The Law Offices of Daniel N. Price, PLLC provides domestic and international tax services, IRS representation and defense, and much more. Daniel “Dan” Price is the managing member of the firm.

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Dan’s legal practice focuses on federal tax and Title 31 matters including civil defense of IRS audits and criminal defense of IRS criminal investigations. Are you facing a major IRS issue? Whether the issue is personal or corporate, domestic or international, Dan may be able to provide insightful counsel and defense. Dan can assist with evaluating whether and how to respond to IRS letters, summonses, and other contact. Trending issues range from employee retention credit claims to taking positions that a pension plan is entitled to deferral under an income tax treaty. If the IRS is focusing on a transaction, and you or your company engaged in the transaction, then consider talking to Dan.

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Dan also assists taxpayers in navigating the process of coming into compliance, especially taxpayers with significant reporting obligations who have for one reason or another failed to comply fully with U.S. tax and Title 31 laws. Dan handles personal income tax, corporate tax, Form 720 excise tax (for example, aviation excise taxes for air transportation and fuel under I.R.C. § 4261, foreign insurance premium excise taxes under I.R.C. § 4371, etc.), partnership issues, international tax reporting matters, and foreign bank account reporting. Regardless of the past filing obligation, if you need help, then Dan may be able to assist.

Dan’s deep expertise concerning the IRS’ Voluntary Disclosure Practice, the Streamlined Filing Compliance Procedures, and international penalty regimes allows him craft strategies to mitigate civil penalties and criminal exposure. Dan further assists taxpayers in battling significant penalties assessed by the IRS and certain state tax authorities. When it comes to penalties, Dan understands the penalty abatement and refund process from start to finish including how to sue the IRS to recover penalties. The type of penalty does not matter. From business information return penalties for Form 1094-C and Form 1095-C to international penalties for Forms 3520 and Forms 5471, Dan knows IRS penalties and how to battle them. Did your CPA make a mistake prompting the IRS to assess significant penalties? Then, contact Dan for a consultation.

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Dan’s expertise and legal services extend to many more areas of tax law. Dan defends taxpayers involved in IRS collection including those who receive notices of federal tax lien and notices of levy. If the IRS issued to you a Notice of Determination Concerning Collection Actions under Sections 6320 or 6330 of the Internal Revenue Code and you want to fight the Notice of Determination in Tax Court, then contact Dan. Did your current or former spouse leave you with huge tax liabilities? You may be entitled to innocent spouse relief. Do you have information about significant tax evasion by a company or an individual? Dan may be able to assist you with filing an IRS Form 211 whistleblower claim. Are you trying to make a Freedom of Information Act (FOIA) request for your case file from the IRS? Dan can assist you with FOIA requests and FOIA appeals.

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Are you a tax attorney needing specialized assistance? Dan may be able to co-counsel your tax litigation, provide expert testimony on certain IRS programs, or even serve as a co-mediator for your mediation with the IRS Independent Office of Appeals in Post-Appeals Mediation or other alternative dispute resolution. Dan can also co-counsel your settlement conference before the IRS Independent Office of Appeals whether the conference relates to docketed Tax Court litigation or non-docketed matters.

 

Experience

Dan’s past government experience includes significant contributions to IRS tax enforcement. For example, Dan assisted the IRS in completely revising the Voluntary Disclosure Practice including the new instructions for Form 14457. If you would like more information about the IRS’ Voluntary Disclosure Practice, Dan authored a guide for non-attorneys entitled “A Plain Language Handbook on the IRS Voluntary Disclosure Practice.”

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Dan’s government experience also included the Offshore Voluntary Disclosure Program, the Streamlined Filing Compliance Procedures, expatriation, foreign bank account reporting (FBAR), Bank Secrecy Act investigations, LB&I compliance campaigns, and more. Dan also litigated tax cases in the United States Tax Court. For a sample of cases Dan has litigated in the United States Tax Court, see this summary.

 

San Antonio office address (by appointment only): 1175 W. Bitters Rd. Ste 2203, San Antonio, TX 78216