Tax Controversy & IRS Audit Defense
The Fuller Tax Law Group represents Fortune 500 companies and other large employers in high-stakes IRS audits, tax controversies, and litigation. With leadership experience from the IRS National Office, Am Law 100 firms, and private industry, we serve as strategic advisors on the most complex federal tax disputes—including fringe benefits, worker classification, and payroll tax compliance.
We partner closely with in-house tax departments, payroll teams, and outside counsel to navigate bet-the-company audits, particularly those involving federal employment taxes, independent contractors and fringe benefits.
Proactive Counsel Beyond Audit Defense
Our practice goes beyond defending audits. We emphasize proactive tax planning, compliance reviews, and risk management strategies designed to prevent IRS scrutiny before it arises. Clients trust us not only to resolve disputes efficiently but to build sustainable compliance practices that reduce future risk.
Strategic Focus on High-Risk IRS Audit Areas
We focus on the tax issues most frequently targeted by IRS audit initiatives and enforcement campaigns, including:
→ Fringe benefit taxation, including executive use of corporate aircraft
→ Federal employment tax compliance (FICA, FUTA, and income tax withholding)
→ Independent contractor classification and contingent workforce compliance
→ Payroll tax exclusions and refund claims under Sections 3121 and 3401
→ Defense against tax penalties and advocacy for reasonable cause abatements
Minimize Risk Through Early, Effective Resolution
Our priority is securing favorable outcomes at the Exam and IRS Appeals stages—minimizing financial exposure and business disruption. We proactively assess audit risks, develop comprehensive defense strategies, and leverage underutilized IRS relief provisions. Where possible, we help clients pursue concurrent refund claims to mitigate audit risks.
Prepared for Every Stage: From IRS Examination to Litigation
With the IRS expanding its employment tax audit initiatives, particularly in payroll tax compliance, we expect increased litigation in the years ahead. When administrative resolution is not achievable, our attorneys—armed with deep technical knowledge and prior government service—work seamlessly with litigation counsel to defend your interests in court.
Your Partner in Tax Controversy and IRS Defense
From audit readiness and compliance reviews to litigation strategy, The Fuller Tax Law Group stands ready to guide your business through every phase of IRS controversy. We deliver trusted counsel with the integrity, technical excellence, and strategic focus that define our firm.
Why Fuller Tax Law Group?
→ Former IRS National Office and Big Law attorneys
→ Deep bench in employment tax and executive compensation
→ Strategic thinking guided by integrity, discretion, and sound judgment
→ Proven success in IRS audit, appeals, and litigation matters
Get Ahead of IRS Enforcement
With the IRS intensifying audits—particularly around payroll tax and contingent workforce issues—proactive legal guidance is essential. Let us help you prepare, defend, and win.
