TAX CONTROVERSY
Donovan Legal PLLC represents businesses and high-net-worth individuals in federal and state tax disputes — from the first notice through examination, administrative appeal, and litigation in the United States Tax Court.
The firm has handled multiple multi-million-dollar matters across the country addressing income tax, partnership tax, and sales-and-use tax issues. It appears before the Internal Revenue Service, state departments of revenue, and administrative tribunals, and pursues judicial review where the matter cannot be resolved at the agency level on acceptable terms.
A letter from the IRS is a countdown.
Most of them carry a deadline that cannot be reopened once it passes. Find out which one you are holding.
Scheduling does not create an attorney-client relationship. No such relationship exists until the firm has run a conflicts check and both sides have signed a written engagement agreement.
A NOTICE IS A CLOCK
Most people who receive a tax notice put it aside. That is the one thing the system does not forgive.
Almost every door in a tax dispute is gated by a statutory deadline running from the date printed on a notice, and some of those doors close in as few as thirty days. A response window that closes does not reopen. The forum behind it is simply gone, and the matter proceeds without the argument that would have been made there.
The first question in any controversy engagement is therefore the same: what is the date on your notice?
THE MAP
The federal tax controversy process end to end. Each stage is described below; the full procedure is set out in the controversy roadmap.
Federal tax disputes are not random. The system has a structure — stations, junctions, and a set of well-worn roads between them. The difficulty is that the structure is rarely explained to the people standing inside it. Each stage below has a page describing how the firm handles matters there.
MATTERS THAT ENTER FROM OUTSIDE THE MAP
Not every controversy begins with a notice. Some begin with the absence of a return.
Unfiled Returns & Non-Filers — options are widest before the Service makes contact.
Foreign Accounts & Voluntary Disclosure — FBAR, FATCA, streamlined filing, and voluntary disclosure.
Penalties & Abatement — reasonable cause, first-time abatement, and the accuracy-related penalty regime.
Partnership Audits (BBA) — partnership representative work, push-out elections, and imputed underpayments.
STATE TAX CONTROVERSY
State disputes run on their own procedure and their own clocks, and the deadlines are frequently shorter than the federal equivalents. The firm maps two states in detail and represents taxpayers in residency disputes wherever it may appear.
WHY DONOVAN LEGAL
Attorney and CPA
One person reads the Code, the regulations, the partnership agreement, and the entries on the return. An examination moves on all four at once.
We can go to court
A law firm files the petition and tries the case. That is not a slogan — it changes what Appeals will pay to settle, because the hazards are real.
One signature
Every return that leaves this firm is signed by Paul K. Donovan personally. Not an associate, not a contractor.
No handoff
The firm that designs the position reports it and defends it. There is no transfer at the moment a transfer costs the most.
Thirty years
In real estate and partnership tax specifically — the issues that decide most examinations in this asset class.
Privilege by design
Where accounting analysis has to sit inside the privilege, it is engaged under Kovel, for the law firm rather than alongside it.
WORKING WITH YOUR EXISTING ADVISORS
Most controversy matters arrive by referral. The firm is scoped to the controversy itself — the legal defense, the communications with the taxing authority, and the privilege. Your compliance advisor stays in place and is included as the facts and the ethics rules require.
The firm can handle the underlying return work through its tax compliance practice, so the position, the return, and the defense stay under one roof and one signature.
The same firm that designs a position reports it, and defends it if it is challenged.
One firm · one signatureHOW AN ENGAGEMENT BEGINS
Book a free consultation
Thirty minutes, no charge. Bring the notice — we read it together on that call.
The deadline is identified
Which notice it is, what it asserts, and which forums are still open behind it.
Conflicts check and written engagement
Scope and fee agreed in writing before any work begins.
HOW A CONTROVERSY RESOLVES
The firm takes over
Correspondence with the Service runs through the firm. You stop answering.
The position is built and pressed
Records, authority, and the argument — pressed at the earliest stage that will take it, because that is the cheapest place to win.
Resolution
Closed at examination, settled at Appeals on the hazards, or tried. The firm does not hand the file to anyone to reach the last of those.
Representation begins with a confidential assessment of the notice, the deadline running against it, and the options that remain open. Contact the firm through the contact page or call (561) 666-6022. Representative engagements are described on the Experience page.
(561) 666-6022 | info@donovan.law
Donovan Legal PLLC · Delray Beach, Florida