Tax Controversy

Stephen J. Pieklik, F. Jefferson Bragdon, and Michael E. Lloyd comprise the Williams Coulson Tax Controversy Practice Group. With more than 30 years’ experience in IRS collection and other tax controversy matters, they have handled virtually every kind of dispute a taxpayer can have with the IRS.

Our attorneys routinely represent clients at various stages:


Representing clients in IRS Collection status including: negotiation of “partial pay” and “full pay” installment agreements; negotiation of offers in compromise and doubt as to liability offers in compromise (including planning for a successful offer in compromise); securing release of bank and wage levies and lien withdrawals; and obtaining penalty and interest abatement.

FBAR and Offshore Matters

Advising clients about Foreign Bank Account Report (FBAR), Foreign Account Tax Compliance Act (FATCA), and other information reporting requirements; assisting clients in FBAR and FACTA compliance including participation in IRS forgiveness programs, and representing clients with FBAR and FACTA penalties.

Criminal Tax Matters

Representing clients at sensitive income tax audits with potential to be referred to the IRS’s Criminal Investigation Division; representing clients under IRS criminal investigation before referral for prosecution, negotiating fraud penalties.

 IRS Audits

Representing clients in audits with respect to: individual and business income taxes, employment taxes (including trust fund recovery penalty cases), retirement and employee benefit plans, tax shelter and listed transaction participation, captive insurance, and excise taxes; and representing clients with respect to: claims of innocent spouse relief, and summons enforcement.


Representing clients in appeals of assessments and other matters within the IRS (the IRS Office of Appeals), and in Tax Court and U.S. District Court.