Irs chief counsel san jose




















Nicholas Rosado is a trusted San Jose, CA tax attorney offering high-quality tax controversy and compliance services. He has an unparalleled breadth of legal experience having both represented mid-size and large businesses at a private law firm, and represented the government as a Senior Attorney for the IRS Office of Chief Counsel.

In addition to his far-reaching experience in tax controversy and compliance regarding individuals and businesses, he is one of a handful of attorneys in the United States who has represented the IRS in litigation and enforcement regarding the cannabis industry. Call Nicholas Rosado at or request a free consultation online now. He has tried more than 20 cases in the United States Tax Court. Rosado was one of a handful of attorneys at IRS Counsel tasked with litigating and providing legal advice to the IRS on all issues involving enforcement of the Cannabis Industry.

He was also solely tasked with litigating all whistleblower cases filed in the Northwestern United States. In addition to focusing on these specific areas, Mr. Rosado has litigated cases involving a broad array of tax issues, and has successfully resolved more than United States Tax Court cases.

Rosado regularly provided legal advice to IRS Examination. In that role, he provided daily legal advice to the Fraud Enforcement Advisor covering Northern California and Revenue Agents on developing the fraud penalty in ongoing examinations.

In those cases, he provided legal advice to Examination teams working on complex audits of high wealth individuals and organizations. Rosado has broad experience with IRS Collection. He has authorized lawsuits ranging from injunctions for employment tax pyramiding to lien foreclosures. Virtual Settlement Day VSD events will be conducted by every Chief Counsel office across the country and will serve taxpayers in all 50 states and the District of Columbia.

These communications can aid in reaching a settlement by providing taxpayers with a better understanding of what is needed to support their case. If settlement is reached, IRS Collection personnel will be available to discuss potential payment alternatives. For those who choose to take their cases to court, the VSD process can also help by giving taxpayers a better understanding of what information they need to present to the court to be successful.

Local Taxpayer Advocates and their staff can work with and inform taxpayers about how TAS may be able to assist with other unresolved tax matters, or to provide further assistance after the Tax Court matter is concluded.

If a taxpayer experiences difficulties concerning collection, TAS can also assist with collection alternatives. How does one go about participating in a VSD event? The IRS proactively identifies and reaches out to taxpayers with Tax Court cases which appear most suitable for this settlement day approach.

The IRS first announced virtual settlement days in May of last year.



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