CARF Tax Litigation
Defense in federal administrative tax proceedings and in appeals submitted to CARF.
Federal administrative tax litigation has its own stages for the assessment and discussion of the tax credit. CARF rules on appeals within its jurisdiction, and is not the first instance for every tax dispute. The defense strategy depends on the deficiency notice or the challenged decision, the facts proven and the issues that can be considered at each stage. Organizing documentation from the outset influences the scope of later discussions.
The work involves analyzing the assessment, preparing challenges and appeals, and monitoring judgments, depending on the procedural stage. Accounting evidence, contracts and financial statements must align with the legal grounds of the defense. Admissibility requirements, precedents and the consequences of judicial measures related to the same matter are also examined. The assessment of alternatives must distinguish between administrative discussion, voluntary regularization and a possible judicial route, considering the effects of each choice on enforceability and the continuation of the dispute.
Our work
- Challenges and analysis of deficiency notices
- Appeals and monitoring of CARF judgments
- Organization of documentary and accounting evidence
Does CARF judge every tax assessment?
No. Its jurisdiction falls within federal administrative tax litigation. State and municipal taxes have their own administrative channels, and not every federal dispute reaches the Council.
Editorial review: