Federal Tax Litigation Attorney Joseph R. Viola Aggressively Pursues Your Case and Protects Your Rights
If the available administrative procedures for asserting your IRS tax controversy have failed to produce a just outcome, litigation in federal court is your final option and last resort. If you decide to sue the IRS in Court, you need the professional representation and personal service of an experienced tax litigation attorney.
With almost 30 years of successful experience behind him serving a broad range of clients including those with federal tax law disputes and problems, Joseph R. Viola has proven that he can help people just like you. He knows federal tax law and procedure, knows the federal judicial system and knows how the prepare and present the most persuasive possible case at trial in the event the case cannot be favorably concluded without a judge's final decision.
When you are ready to exercise your legal right to have your federal tax case resolved in court, contact our trusted Pennsylvania and New Jersey law office. Call 866-974-8841, toll free.
Joseph R. Viola, P.C. serves clients in cities such as Philadelphia, Norristown, Media, Conshohocken, West Chester, Doylestown, King of Prussia, Drexel Hill, Ardmore, Bala Cynwyd, Bryn Mawr, Berwyn, Devon, Malvern, Merion, Paoli, Radnor, Rosemont, Villanova and Wayne; and New Jersey cities such as Cherry Hill, Voorhees, Moorestown, Camden and Marlton.
Almost 30 Years of Service to Greater Philadelphia, the Delaware and Lehigh Valleys, and South Jersey
The United States Tax Court is a federal court based in Washington, D.C. with 19 Judges who travel to 60 major cities around the country to conduct trials. As the name indicates, the Court hears only tax cases. The most often cited feature of this court is that a taxpayer assessed with a deficiency who filed a timely petition with the Tax Court is not required to pay the disputed deficiency while the case is pending; interest continues to accrue, however. The Tax Court handles about 25,000 petitioners a year, 90 percent of which are settled without significant input from a Tax Court Judge.
Not all federal tax disputes can be heard in the Tax Court, however. In addition, there are advantages and disadvantages to choosing the Tax Court to litigate your particular case.
As an alternative to proceeding to the Tax Court, as well as in cases that cannot be filed in the Tax Court, the taxpayer can pay all or some of the disputed tax, file a claim for a refund, and, when six months has elapsed or the claim has been denied, file a refund action against the IRS in the United States District Court in the federal District in which the taxpayer resides. The District Courts are busy courts of broad jurisdiction with no special tax expertise. Again, there are advantages and disadvantages to filing your case in the District Court.
There is a third federal court in which taxpayers can file their case against the IRS: the United States Court of Federal Claims. That court was created to handle all varieties of monetary claims against the Federal Government and, like the District Courts, has no particular federal tax expertise, although one quarter of its normal case load consists of federal tax refund cases.
The Court of Federal Claims, which consists of 16 Judges, is located in Washington, D.C., and generally holds its trials there. Like the District Courts, the Court of Federal Claims is a "pay first" forum. Because of the travel costs involved, litigation in the Court of Federal Claims can be significantly more expensive than litigation in Tax Court or the local District Court. Still, under certain circumstances, it can be in the taxpayer's best interest in file in the Court of Federal Claims.
In addition to the Tax Court, the District Court, the Court of Federal Claims, the local United States Bankruptcy Court can hear and decide most tax cases. Bankruptcy Court is only available to taxpayers already involved with bankruptcy proceedings.
Joseph R. Viola is admitted to practice in the Tax Court, the Court of Federal Claims, and the District Courts and Bankruptcy Courts of Pennsylvania and New Jersey.
We invite you to contact Joseph R. Viola, P.C. today at this toll-free phone number: 866-974-8841. You will be assured of the highest possible level of professional representation and personal service.
Contact Our Experienced Philadelphia Federal Tax Litigation Attorney
Joseph R. Viola is a Pennsylvania lawyer with the proven skills, client commitment and reputation for results you can trust.
