Tax Planning & Controversy

Nardone Limited represents individuals and businesses in federal (IRS), state, and local civil tax controversy matters. This representation extends from the initial audit and examination conducted by the taxing authorities to the administrative appeals process, court review, and collection matters. Nardone Limited has extensive expertise in handling matters with the Internal Revenue Service, Ohio Department of Taxation, other state taxing authorities, and many municipalities within Ohio.

As former Department of Justice Tax Division personnel and tax law specialists, the attorneys and professional staff at the Nardone Limited provide aggressive high quality representation before the Internal Revenue Service ( IRS ), Ohio Department of Taxation, and local taxing authorities. These services include audit defense, substantive tax litigation and collection matters. Taxpayers are entitled to many protections while under IRS audit, tax audit or investigation in tax controversy and the services of experienced tax counsel can reduce the potential for an adverse determination. When negotiation with the administrative arm of the IRS fails to secure a desired resolution, we have the experience to pursue judicial remedies to assure that our clients only pay the proper amount of tax and to minimize any criminal aspects of an investigation.

  • Advising on what it takes to perfect a voluntary disclosure and how to do it
  • Working with clients in correcting prior tax problems
  • Negotiating with IRS agents and officials
  • Preserving the benefits of a voluntary disclosure so criminal prosecution is avoided


What type of IRS or Ohio Department of Taxation tax cases can we help with?

Representative engagements include:

  • Representing individuals, estates, and businesses in audits, appeals, and substantive civil tax litigation matters
  • Representing individuals and businesses in tax collection matters – with a focus on Internal Revenue Service administrative collection matters, including successfully obtaining offer-in-compromises, installment agreements, and other collection alternatives on behalf of clients
  • Representing individuals in bankruptcy court as part of discharging their qualified federal, state, and local income tax liabilities
  • Representing troubled businesses with their federal, state, and local tax obligations and negotiations with the various taxing authorities
  • Representing tax professionals, including certified public accountants, in administrative professional proceedings before the Internal Revenue Service, Office of Professional Responsibility, and in malpractice cases

Representative sample of substantive civil tax litigation matters:

  • Worker Classification Audit – Successfully defended businesses from the Internal Revenue Service’s attempt to re-characterize independent contractors as employees
  • Trust Fund Investigations – Successfully defended individuals from the Internal Revenue Service’s attempt to target and characterize individuals as responsible persons for purposes of the trust fund recovery penalty
  • Assisted a divorced woman in obtaining a multi-million dollar tax refund that the Internal Revenue Service erroneously refunded to her ex-husband
  • Successfully defended a taxpayer’s avoidance of discharge of indebtedness income because of the taxpayer’s insolvency at the time of such discharge
  • Assisted a woman in avoiding being responsible for her husband’s tax liabilities by successfully arguing that she was an innocent spouse as that term is understood for purposes of the Internal Revenue Code
  • Represented estate representatives in defending against the Internal Revenue Services’ attempt to increase estate tax liabilities by arguing that certain assets were part of or should be part of the estate for estate tax purposes
  • Successfully represented estates in properly discounting interests in a family limited partnership for estate tax purposes
  • Represented tax shelter investors in audits and appeals matters with the Internal Revenue Service

Please see attorney Vince Nardone’s tax blog at