For the vast majority of tax disputes, the Rules of Administrative Law apply. Administrative law, commonly called regulatory law, includes those rules and regulations enforced by an administrative body. This is a significant part of every tax lawyer’s education and practical experience. At the administrative level, the tax issue must be documented and researched thoroughly to properly exhaust all available administrative remedies — completely. Tax attorneys know what these rules are and can find hidden issues that can be won in many cases.
A tax attorney has the ability and knowledge needed to present a case so compelling that IRS appeals officers will accept a settlement. This is a terrific benefit to taxpayers as these settlements are a relatively inexpensive and quick resolution compared with litigation with the US government. A tax attorney knows that it is always best to avoid tax court.