IRS Litigation
Tax Court, refund suits and collection due process — tried, not merely negotiated. We take the file assuming it ends in front of a judge.
Read more Privileged · ConfidentialHigh-Stakes Tax Disputes,
High-Stakes Tax Disputes,
Decisive Legal Resolution
Vangarde Tax Counsel defends individuals, closely-held businesses and multinationals against the IRS in the matters that carry real consequence — criminal referrals, offshore disclosure, and nine-figure examination exposure.
Adrian Voss, J.D., LL.M.
Managing Partner · Tax Controversy
- $450M+
- Tax liabilities mitigated
- 1,300
- Matters resolved pre-litigation
- 30+
- Years at the tax bar
Performance Analytics
Case Trends & Success Rates
Assessed liability across the firm's docket, filterable by practice line.
Case trends & resolution outcomes
Assessed liability across the firm's docket, and how much of it never reached judgment.
$451M
Peak assessed liability, current year
89%
Resolved before judgment
112
Matters tried, current year
Interactive Tool
Assess Your Exposure
A quick triage of posture, quantum and open years.
Our Process
High-Stakes Resolution
From privileged intake to closing agreement.
01Privileged Intake
A protected first conversation. We map the exposure, the statute of limitations and every open year before a single document leaves your office.
- Conflict check→
- Kovel engagement→
- Exposure map
02High-Stakes Resolution
Examination defence and Appeals advocacy run in parallel with a litigation-ready record, so settlement is a choice rather than a necessity.
- Examination defence→
- IRS Appeals protest→
- Settlement or trial
03Post-Resolution Shielding
Closing agreements, penalty abatement and a compliance posture that keeps the next cycle from reopening what we just closed.
- Closing agreement→
- Penalty abatement→
- Ongoing compliance
Practice Areas
Core Legal Competencies
Specializing in high-stakes tax defence and litigation.
International Tax
Voluntary disclosure, treaty relief and cross-border structuring for clients whose exposure spans several jurisdictions at once.
Read moreCriminal Tax Defence
Representation from first CI contact through indictment, with the objective of ending the matter civilly wherever the facts allow.
Read moreBusiness Tax Strategy
Audit-ready positions, reasonable-cause files and penalty abatement built before an examiner ever opens the return.
Read moreRegulatory Insights
From the Practice
Analysis on the rulings and notices that move client exposure.
FBAR
August 11, 2026
What the latest FBAR penalty ruling changes for non-willful filers
The per-report reading of §5321 has narrowed exposure sharply — but only for taxpayers who can document the reasonable-cause record.
Read moreLB&I
July 28, 2026
Corporate audit campaigns: reading an LB&I notice before you answer it
Campaign letters signal the theory of the examination. The first response frames every concession available for the next two years.
Read moreCriminal
July 04, 2026
How a civil examination quietly becomes a criminal referral
Certain examiner behaviours are reliable tells. Recognising them early is the difference between a penalty and an indictment.
Read moreGet In Touch
Protected Communication
Location
412 Meridian Row, Suite 2200, New York, NY
24/7 Rapid Defence
Motto
Vangarde Tax Counsel is a coalition of former IRS trial attorneys, retained the moment a matter stops being routine.