Tax Controversy Services
Protect Your Business
Omega is committed to bringing our clients a full compliment of tax services and our Tax Controversy group is ready to use our extensive knowledge and experience of tax law and procedure to give you the best possible representation in any interaction you have with the IRS. Our staff, headed by Tracy Martinez, an attorney with over thirty years of experience with the US Department of Justice, Tax Division and the IRS Office of Chief Counsel, and now representing taxpayers can handle tax audits, administrative appeals, IRS collection matters, pre-litigation counseling, Tax Court and District Court proceedings, representation in investigations by the IRS Criminal Investigation Division, and other services to assert your rights before the IRS.
As part of our tax credits and incentives services here at Omega, including Employee Retention Credits, Research and Development, FICA tip credit, and others, our Tax Controversy group provides rigorous consulting, review, and representation from the very beginning of the process with the goal of avoiding challenges by the IRS once your credits have been claimed.
Capabilities
How Omega Helps
We take a proactive and thorough approach to tax credit and controversy services, helping your business stay ahead of potential challenges. Our Tax Controversy group is here to help clients navigate disputes with the IRS, including challenges to tax credit claims, income tax audits, employment tax and trust fund penalty investigations, failure to file returns or pay taxes, and a variety of other investigations and questions that can arise. Our decades of experience gives us a comprehensive understanding of tax laws, regulations, compliance issues, and the procedural and substantive aspects of tax audits, appeals and litigation.
Representation
The Tax Controversy Group at Omega can represent your interests during all phases of a tax dispute, including audits, administrative appeals, bankruptcy consultation if tax debt is owed, collection matters, criminal investigations, pre-litigation planning, and representation in courts.
Tax Controversy is a highly technical and specialized area and it is important to have a team on your side that has years of experience dealing with the IRS. Our representation ensures that Omega clients have knowledgeable and experienced legal support when navigating disputes with the IRS.
Tax Issues
At Omega, we assist clients in navigating complex tax issues by providing tailored solutions and strategic support. Our services range from ensuring accurate compliance and risk assessment to representing clients in IRS disputes. Whether you need guidance in substantiating claims, responding to audits, or resolving collections notices, our expert team is here to minimize risks and protect your business’s financial well-being.
Audit & Administrative Appeals
Our audit support services include a detailed review of your tax return and financial documents, strategic audit preparation, and direct representation before the IRS. We’ll handle all communications, help gather necessary documentation, and develop a personalized defense strategy. From negotiating settlements to appealing unfavorable outcomes, our goal is to achieve the best possible resolution for your audit.
Representation by an experience tax controversy attorney from the beginning of an IRS audit can make the difference between a fast and favorable resolution of the issues. Our Tax Controversy group can assist you in audit strategy, document production, representation before the Revenue Agent, and negotiation of a settlement if a 100% victory is not possible. If the audit or collection matter remains unresolved, we provide full appeals support and representation before the IRS Office of Appeals
ERC Risk Assessment
Gain clarity and peace of mind about your clients’ ERC claims with our comprehensive ERC portfolio risk assessment service. Our ERC portfolio risk assessment is designed for any business that has submitted an ERC claim, including PEOs whose have filed claims on behalf of their clients and are uneasy about the potential risk that comes with it. We offer a thorough review of your clients’ ERC claims to identify potential risks and ensure compliance with IRS guidelines. Our detailed analysis will highlight any areas of concern, provide recommendations for mitigating risks, and help you maintain the highest standards of accuracy and compliance.
Tax Controversy Consulting
The participation of our Tax Controversy Group in all phases of our credits and incentives programs and our accounting consultation services provide our clients with up-front review and support as clients are best served when disputes and litigation with the IRS are avoided in the first place. Our group uses their extensive experience and expertise of complicated tax procedures and substantive issues to counsel our clients on their business operations, structures, and planning strategies that are geared toward dispute avoidance, but is able to take on any challenges that arise. From an initial consultation about specific issues to on-going support to your CPA or in-house accounting team, our Tax Controversy group will provide you with important risk management strategies and support when you are facing future or current issues with the IRS.
Trending Insights
Kwong v. United States: Did You Pay Penalties and Interest During the COVID-19 Pandemic that Were Not Really Due?
A recent decision by the U.S. Court of Federal Claims in Kwong v. United States, 179 Fed. Cl. 382 (2025), introduced an important new...
Navigating New IRS Changes: Key Updates & Requirements for the R&D Tax Credit
Part I: Changes to IRS Form 6765 On June 21, 2024, the IRS released a new draft version of Form 6765, Credit for Increasing Research...
The Impact of the H.R. 7024 Tax Relief Bill on American Businesses
Experience a groundbreaking moment as the Senate embraces the future with the approval of H.R. 7024 – The Tax Relief for American Families...
Tax Expert Team
Tracy Anagnost Martinez, JD, LLM
Senior Director, Tax Controversy
Tracy is the leader of our Tax Controversy group at Omega. She brings 35 years of experience in tax controversy matters, serving as a Senior Attorney with the US Department of Justice, Tax Division, a Senior Attorney with the IRS Office of Chief Counsel, and as a representative for taxpayers with disputes before the IRS. She holds an LLM from Georgetown University Law Center, JD from Albany Law School of Union University, and a BA in International Relations from Colgate University. Tracy enjoys assisting clients across the various stages of IRS interaction, including pre-audit support, audit and investigations representation, appeals and litigation, and other matters involving IRS disputes.


