The firm's philosophy is that every Federal Tax dispute boils down to investigating and proving facts and applying the applicable law to those particular facts in a just and reasonable manner, which remains the territory of the litigator, not the tax "specialist." A law firm with litigation as well as broad tax law expertise can effectively promote the quick, cost-effective and fair resolution of a tax dispute at the administrative level, and, if resolution is unlikely, can immediately file a court action, proceeding only as far as is necessary and appropriate to obtain the optimal result.
Joseph R. Viola, P.C., recognizes that the key to effective representation -- in federal tax and any other matters is developing a cordial relationship of mutually respect and trust with each client. This can only be achieve through personal attention, responsiveness and accessibility on the attorney's part and openness and cooperation on the part of the client. The process works best when the client is kept informed and regularly consulted.
Matters in which representation is available include: IRS Audits & Examinations; IRS Liens, Levies & Seizures; IRS Installment Agreements & Offers in Compromise; FBAR, FATCA and Offshore Voluntary Disclosure Initiatives; Relief from Joint & Several Liability (“Innocent” Spouse Relief); Trust Fund Recovery Penalty; Abatement of Civil Penalties; IRS Administrative Appeals; U.S. Tax Court Petitions;
Refund Litigation Against IRS in Federal Courts; Private Letter Rulings; and IRS Audit Reconsideration.
Specific Areas of Practice for our Philadelphia office: