Tax Controversy


The U.S. Supreme Court recognized as early as 1819 that “[t]he power to tax involves the power to destroy.” More than a century later, Albert Einstein proclaimed: “The hardest thing in the world to understand is the income tax.”

It’s a scary combination—“the hardest thing in the world to understand” has “the power to destroy”—but we’re here to help.

Two Former Federal Tax Prosecutors in Your Corner

Justin Gelfand and Greg Bailey began their legal careers prosecuting federal tax cases with the U.S. Department of Justice’s Tax Division.  Based in Washington, D.C., each of them handled complicated tax cases throughout the United States at the investigation, trial, and appellate levels.  Justin was a faculty member at the Justice Department’s acclaimed legal academy in South Carolina, where he taught hundreds of federal prosecutors the ins and outs of criminal tax cases.  Justin also trained more than 1,000 IRS and Treasury agents in 15 states on investigative techniques unique to tax cases.  Since leaving the Government, Justin routinely presents continuing education to attorneys and accountants throughout the country on cutting edge civil and criminal tax issues.

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We Represent People and Businesses

Whether working with individuals or businesses, we do everything we can to reach out-of-court resolutions when our clients want that—but we also have experience in all relevant forums including the United States Tax Court, United States District Courts, the Missouri Administrative Hearing Commission, United States Courts of Appeal, and before the IRS and Missouri Department of Revenue.

We’re Here to Assist in the Following Areas:

  • IRS Audits and Appeals
  • Tax Court Litigation
  • District Court Litigation
  • Innocent Spouse Cases
  • Employment Tax and Trust Fund Recovery Penalty Cases
  • Tax Collection Matters
  • Representing Tax Return Preparers, Including CPA’s, Enrolled Agents, and Unlicensed Preparers
  • Sensitive IRS Audits (“Eggshell Audits”) with Possible Criminal Exposure
  • Criminal Tax Investigations and Litigation
  • Offshore Account Disclosures, FBAR Compliance Issues, and Voluntary Disclosures
  • State Audits and Appeals
  • Tax Whistleblower Matters