Tax Litigation and Controversy

Tax controversy attorney and CPA team analyzing IRS dispute documentation in law office
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Tax Controversy CPA in Jacksonville

When a disagreement with the IRS or the Florida Department of Revenue cannot be settled with a simple letter, you need experienced help. Tilbrook CPA works with individuals and businesses facing proposed assessments, denied refunds, and penalties they believe are wrong. As a tax controversy CPA in Jacksonville, we review the facts, organize the evidence, and present your position clearly and professionally. Common issues include disallowed business deductions, worker classification, unreported income claims, trust fund recovery penalties, and sales tax assessments. We serve Jacksonville, Orange Park, Ponte Vedra, St. Augustine, and Fernandina Beach. Call (904) 477-3369 to discuss your case.

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IRS Appeals and Tax Dispute Resolution

Most tax disputes are resolved before they ever reach a courtroom. If you disagree with an audit result, we can prepare a formal protest and represent you before the IRS Independent Office of Appeals. We also handle Collection Due Process hearings, penalty appeals, and offer in compromise negotiations. Our goal is a fair settlement that limits your cost, stress, and time. Our dispute services include:

  • Written protests of proposed audit adjustments
  • Representation at IRS Appeals conferences
  • Collection Due Process and equivalent hearings
  • Penalty abatement appeals
  • State tax dispute resolution with the Florida Department of Revenue
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Tax Litigation Support CPA for Your Legal Team

When a case moves to the U.S. Tax Court or another court, you will usually need a tax attorney. We work alongside your attorney as the financial expert on the case. That support can include rebuilding records, calculating tax and interest, analyzing transactions, preparing schedules and exhibits, and serving as an expert witness. Our combined approach helps your legal team build a stronger, well-documented case.

Senior tax litigation specialist preparing legal defense brief for U.S. Tax Court proceeding
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Experience That Protects Your Interests

Jim Tilbrook brings more than 20 years of financial leadership, including work with the Florida Auditor General and as a corporate Controller and CFO. That background gives him a clear view of how tax authorities review records and build cases. We prepare every matter as if it could be reviewed by a judge, so your position is documented, consistent, and credible from the start. We also explain each step in plain language, give you honest odds, and tell you when settling makes more financial sense than fighting. You stay informed and in control of every decision.

Get Help With a Tax Dispute Today

Deadlines in tax disputes are strict. For example, you generally have only 90 days from the date of an IRS notice of deficiency to petition the Tax Court. Do not wait until options run out. Call (904) 477-3369 or email jim@tilbrookcpa.com to schedule a confidential consultation.

Don't Wait Until Tax Season!

Tax specialist analyzing state and local corporate tax allocation metrics on digital dashboard
Business executive and CPA evaluating corporate tax deduction schedules and credit calculations
What is the difference between a tax audit and a tax controversy?

An audit is the IRS or state review of your return. A tax controversy is any dispute that follows, such as a disagreement over the audit result, penalties, or collection action.

Yes. CPAs are authorized to represent taxpayers before the IRS, including at the IRS Independent Office of Appeals, with a signed Form 2848.

Most do not. The majority of tax disputes settle during an audit or at IRS Appeals. If your case does go to court, we work with your tax attorney.

It is a formal IRS letter, often called a 90-day letter, proposing additional tax. It gives you the right to challenge the amount in the U.S. Tax Court before paying.