Practice Areas
Federal Tax Controversy — Start to Finish
Nearly every matter Ric Hulshoff handles involves a dispute with a federal or state tax authority. That singular focus means deeper expertise, sharper strategies, and better outcomes for clients.
Litigation
Civil Tax Litigation & Motions Practice
Experienced federal and state court tax litigation across multiple circuits and jurisdictions.
When a tax dispute cannot be resolved administratively, litigation becomes the path forward. Ric Hulshoff has litigated civil tax matters in federal and state courts across the country — including the United States Courts of Appeals for the Federal, Seventh, Ninth, and Tenth Circuits, the United States Court of Federal Claims, the United States Tax Court, and the United States District Courts in Nevada, Arizona, and Utah.
State court tax litigation is also within the firm’s practice. While Ric is admitted to the state bars of Nevada, Utah, and Arizona and to practice before those state’s courts and the taxing authorities there, Pro Hac Vice appearances (on motion in other states) and recognition by other states’ taxing authorities effectively allows Hulshoff Law to represent clients almost anywhere in the country.
Effective tax litigation requires more than courtroom presence. It requires a thorough understanding of the administrative record, precise legal argument, and the judgment to know when to settle and when to fight. That combination defines how we approach every case.
What We Handle
- U.S. Court of Appeals — Federal Circuit (2024), 7th Circuit (2026), 9th Circuit (2024), 10th Circuit (2024)
- U.S. Court of Federal Claims
- U.S. Tax Court (admitted 1998)
- U.S. District Courts — Nevada (2023), Arizona (2022), Utah (2022)
- State courts — Nevada, Arizona, and Utah
IRS & Admin
Administrative Practice & Audit Representation
Comprehensive representation before the IRS, state, and local taxing authorities at every administrative stage.
Nearly all tax disputes begin—and most end—at the administrative level. Ric Hulshoff represents clients before the IRS, state taxing authorities, and local taxing authorities through every phase of the administrative process: audits and examinations, administrative appeals, and collection due process hearings.
Audit representation is not simply about responding to IRS requests. It is about controlling the record, protecting privileged information, and building the factual and legal foundation that will support the client's position at every subsequent stage — including litigation if necessary.
Settlement negotiation is a core part of this practice. The firm pursues negotiated resolutions aggressively where they serve the client's interests, and is equally prepared to litigate when they do not.
What We Handle
- IRS audit and examination representation
- Administrative appeals before the IRS Office of Appeals
- Collection due process hearings
- State and local taxing authority representation
- Settlement negotiation
Collections
Collections, Liens & Relief
Resolving IRS collection action — from levies and liens to installment agreements and offers in compromise.
IRS collection action moves quickly and can have severe consequences — federal tax liens that cloud title to property, levies that reach bank accounts and wages, and garnishments that disrupt business operations. Prompt, strategic intervention is essential.
The firm handles the full range of collection resolution tools: levy and garnishment release, lien resolution, innocent spouse relief, offers in compromise, and both full-pay and partial-pay installment agreements. Each approach requires a careful analysis of the client's financial position and the IRS's likely response.
Trust fund recovery penalties — which expose individuals to personal liability for a business's unpaid payroll taxes — are among the most serious collection matters the firm handles. Defending against a trust fund assessment requires early engagement and a thorough understanding of the IRS's determination process.
What We Handle
- Levy, garnishment, and lien resolution
- Innocent spouse relief
- Offers in compromise
- Full and partial pay installment agreements
- Trust fund recovery penalty defense
Specialty
Specialty & Emerging Tax Issues
Complex and high-scrutiny areas requiring deep technical knowledge and litigation-ready counsel.
Certain tax matters carry heightened IRS scrutiny, significant penalty exposure, or both. The firm represents clients in several of these specialized areas, including captive insurance arrangements, conservation easements, and foreign tax reporting and offshore voluntary disclosures — all of which have been the subject of aggressive IRS enforcement in recent years.
Return preparer penalties represent another area of focus. Tax professionals facing IRS penalty assertions need counsel who understands both the technical standards and the procedural options available to contest or abate those penalties.
The firm also advises clients in the marijuana industry on the unique federal tax challenges that arise from operating a business that remains federally controlled — including the limitations imposed by IRC Section 280E and the IRS's enforcement posture in this space.
What We Handle
- Captive insurance
- (Syndicated) Conservation easements
- Foreign tax reporting and offshore voluntary disclosures
- Return preparer penalties
- Marijuana industry tax issues (IRC § 280E)
- Employee Retention Credit audits and claim withdrawals
Not sure which area applies to your situation?
Most federal tax disputes involve more than one of these areas. We assess the full picture and build a strategy that addresses every dimension of your matter.