The language of the Internal Revenue Code and U.S. Treasury Regulations often prove ambiguous when applied to fact patterns which arise. As a result, taxpayers often have honest disagreements with the IRS over the amount of tax due from a certain event or transaction. When such a "tax controversy" involves a substantial amount of money the taxpayer has the option of rejecting the position of the IRS and instead opposing that view through the IRS appeals process and ultimately through litigation in United States Tax Court or United States District Court. When a taxpayer and the Internal Revenue Service are engaged in a tax controversy of tax law or fact the taxpayer should evaluate the options of litigating with the IRS and whether litigation with the IRS would be cost effective. Attorney Rubino can represent you before the IRS, pursue taxpayer claims and tax appeals and represent you in tax matters in the United States Tax Court and United States District Court.