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Tax Litigation

Dan’s tax litigation experience in the United States Tax Court includes trying cases involving individuals, corporations, partnerships, and trusts. In 2009, Dan’s tax litigation skill on behalf of the government was recognized by the Office of Chief Counsel, and Dan was named the Attorney of the Year of Chief Counsel’s Small Business/Self-Employed Division. Dan also litigated tax matters in U.S. Bankruptcy Court as a Special Assistant United States Attorney, and Dan served as a Special Assistant United States Attorney to represent the IRS in United States District Court for summons enforcement proceedings.

 

In handling cases before the United States Tax Court, Dan resolves cases through negotiated settlement with the IRS Independent Office of Appeals, by skillful negotiation with IRS attorneys, by trial, and, if necessary, on appeal.

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Dan’s United States Tax Court practice includes:

  • Deficiencies determined by the Commissioner with respect to income, estate, or gift tax

  • Claims for relief from joint and several liabilities (innocent spouse cases)

  • Worker classification cases (i.e., independent contractor or employee)

  • Collection Due Process cases

  • Whistleblower award cases

  • Passport revocation cases

  • Exempt organization status cases

 

For a sample of cases Dan has litigated in the United States Tax Court, see this summary  or visit the Tax Court website (Go to eFiling & Case Maintenance > Search > Opinion > Search by keyword and phrase > enter “Daniel N. Price” in the search field. Then, select “load more” to see results with opinions.) For best results, please search the Tax Court’s website using a PC since mobile devices may display inconsistent results.

 

Dan’s tax litigation practice in other federal courts includes:

  • Refund litigation including penalty refunds

  • FBAR defense and FBAR refund suits

  • Challenges to the enforcement of IRS summonses

  • Suits related to wrongful levy

  • Review of IRS collection actions before levy on principal residence

  • Defense in suits to reduce tax assessments to judgment and other proceedings

  • Suits to challenge incomplete or inadequate IRS FOIA production

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