Summons Enforcement Proceedings

Standing by You in IRS Summons Enforcement Proceedings

Tax litigation is complicated and may involve many complex legal and factual issues. A tax litigation case may be tied to an IRS civil audit or a criminal case or investigation. If this is your situation, the IRS may issue a summons (or a Grand Jury Subpoena in certain criminal cases) in order to determine the accuracy of any tax return, file a “substitute for return” when one has not been filed, assign tax liability to an individual for an IRS tax matter or to collect the tax debt that may be owed.

If you have received an IRS summons, turn to our experienced tax attorneys at Weisberg Kainen Mark, PL. We have extensive experience handling all aspects of IRS tax issues for individuals and businesses. Our firm is committed to helping clients understand their rights and defend them throughout any IRS or criminal tax proceedings. Contact us (LINK TO CONTACT PAGE) today to discuss your tax litigation or tax enforcement matters.

We will work on your behalf, if appropriate, to contest the summons issued against you. Through thorough investigation and an examination of your records, we will address the underlying tax issues involved. An individual may be able to contest a summons if there are legal grounds for an objection. Many summonses are contested on the grounds that:

  • What the IRS is seeking is not applicable to any genuine purpose
  • The IRS already has the information or documents that it is requesting through the summons
  • The summons was issued in order to harass or intimidate (in bad faith)
  • Enforcement of the summons would result in an abuse of process and unnecessary inspection

Third Party Summonses

The IRS may issue a summons to a third party that may have information on your tax issues, such as your CPA, a bank or brokerage firm where accounts are held, or even to your customers or vendors. You can contest these third party summonses, just as you can contest a summons that was issued directly to you.