Tax controversy work is technical, deadline-driven, and unforgiving. These 10 Albuquerque firms handle IRS audits, offers in compromise, installment agreements, payroll tax problems, U.S. Tax Court litigation, and disputes with the New Mexico Taxation and Revenue Department on gross receipts tax and state income tax.
Updated August 14, 202511 min readEditorially independent
These ten firms handle the full range of tax controversy work for Albuquerque clients — IRS audits and appeals, U.S. Tax Court litigation, offers in compromise, installment agreements, payroll tax issues, and disputes with the New Mexico Taxation and Revenue Department on gross receipts tax and state income tax.
How we picked these 10: We cross-referenced peer-reviewed rankings (Best Lawyers, Super Lawyers, Chambers USA), Avvo and Justia client review patterns, state bar specialization listings, and published case results. Firms that appeared consistently across at least two independent directories made the list. We do not accept payment for placement and we do not write sponsored reviews. More on our methodology →
Named Albuquerque Litigation & Controversy-Tax Lawyer of the Year 2013 by Best Lawyers in America. Extensive experience with IRS installment agreements, offers in compromise, income tax, gross receipts tax, gasoline tax, severance tax, jeopardy assessments, and managed audits with the NM Taxation and Revenue Department.
Why they made the list: One of the most-recognized NM tax controversy attorneys by peer ranking and one of the few NM lawyers who routinely handles both federal IRS and state TRD matters.
Albuquerque, NMMid-sizePractice focus: Tax planning, controversy, estate and business tax
Full-service NM firm with a tax practice that handles planning and controversy for businesses and high-net-worth individuals across federal, state, and gross receipts tax.
Why they made the list: Long-standing NM presence with peer recognition in tax practice and a broader corporate bench — useful when the tax issue is one piece of a business or estate problem.
Fee structure
Hourly
Free consultation
Initial call free
Typical client
NM mid-market businesses and high-net-worth individuals
Heritage Albuquerque firm with the litigation bench to handle U.S. Tax Court trials, IRS appeals, and high-stakes tax controversies for businesses and high-net-worth clients.
Why they made the list: Multiple 2026 Best Lawyers 'Lawyer of the Year' designations across NM practice areas. The default for high-stakes tax controversy in NM.
Albuquerque, NMLargePractice focus: Tax planning, controversy, estate and trust tax
Long-established NM firm with a tax practice that integrates with corporate, estate, and regulated-industry work — a fit when tax is part of a larger planning or transactional matter.
Why they made the list: Strong Best Lawyers and Chambers presence for NM tax work and a deep bench in adjacent estate and corporate practices.
Albuquerque, NMMid-sizePractice focus: Business and individual tax, estate tax, NM tax
Long-standing Albuquerque business firm whose tax work supports business owners through planning, formation, and the occasional tax dispute.
Why they made the list: Frequently recognized in Best Lawyers for NM business work; a fit when tax is part of an ongoing business counsel relationship.
Regional BigLaw with an Albuquerque office that pairs tax practice with corporate, real estate, and M&A work — a fit when tax is part of a larger transaction.
Why they made the list: Wide bench and the resources to handle complex U.S. Tax Court or M&A tax matters; recognized across Chambers USA and Best Lawyers.
Boutique that deals exclusively with tax controversy matters — penalty abatement, offers in compromise, audit reconsideration, U.S. Tax Court representation, and bankruptcy-related tax issues. Dale R. Kennedy is both a Tax Attorney and a licensed CPA.
Why they made the list: Dual J.D./CPA credentials, an exclusive tax controversy focus, and a published willingness to handle U.S. Tax Court matters directly.
Tax controversy boutique with NM coverage; team includes former IRS lawyers with combined 50+ years of tax controversy experience.
Why they made the list: Former-IRS bench is one of the strongest predictors of audit and appeals outcomes; one of the few firms with that profile serving the NM market.
Tax controversy boutique with NM coverage. Attorneys hold tax law master's degrees with specialties in IRS dispute and controversy resolution and 40+ years of experience.
Why they made the list: LL.M. (Tax) credentials on staff, a published specialty in IRS controversy, and an established multi-state practice with NM presence.
David W. Klasing (Klasing & Associates — Albuquerque)
Albuquerque, NMBoutiquePractice focus: Dual-licensed Attorney-CPA, federal and state tax controversy
Tax attorney-CPA with NM coverage offering creative problem-solving across audits and tax disputes, with a published focus on controlling information flow during audits and presenting persuasive arguments at every stage.
Why they made the list: Dual J.D./CPA credentials, published case-resolution data, and an integrated audit-defense-through-litigation model.
Fee structure
Hourly
Free consultation
Paid initial consult
Typical client
Higher-complexity individual and business tax matters
Tell us what you are dealing with in plain English. We will match you with two or three vetted tax / irs firms in Albuquerque that handle cases like yours. Free, confidential, no obligation.
If your matter is a high-dollar IRS audit, a U.S. Tax Court case, or a complex civil or criminal tax investigation, R. Tracy Sprouls, Rodey, Modrall Sperling, or Snell & Wilmer are the firms with the experience and the litigation bench to handle it.
If your matter is an individual IRS debt — a balance you cannot pay, an offer in compromise, an installment agreement, or a wage garnishment — Kennedy Tax Solutions, Silver Law, Segal Cohen & Landis, or Klasing & Associates are the controversy-only boutiques that handle this work day in and day out at boutique pricing.
If your matter is integrated with ongoing business or estate work — tax planning, M&A tax, succession — Sutin Thayer & Browne, Hurley Toevs, or Modrall Sperling are the firms that can do the tax work inside a larger counsel relationship.
What a tax / irs lawyer typically costs in Albuquerque
IRS notice review and response (single letter): $400–$1,500 flat fee at controversy boutiques. The right first step before assuming the worst.
IRS audit defense (correspondence audit): $1,500–$5,000. Most simple audits resolve at this stage.
IRS audit defense (field or office audit): $5,000–$25,000+ depending on years and complexity.
Offer in compromise: $2,500–$7,500 flat fee at most NM controversy boutiques, plus the IRS $205 filing fee (waived for low-income taxpayers). Outcomes depend heavily on financials; an OIC is not a debt-erasure button.
Installment agreement: $750–$2,500 flat fee. Often the right first move for taxpayers with steady income but no lump sum.
Penalty abatement: $750–$2,500. The IRS first-time abatement program is the simplest path; reasonable-cause abatements take more time.
U.S. Tax Court representation: $7,500–$50,000+ depending on stakes and complexity. Hourly billing is the norm.
Criminal tax defense (CID investigation, criminal referral): $25,000–$250,000+. Specialized work; pick a firm with prior criminal tax experience.
NM TRD gross receipts tax audit defense: $2,500–$20,000 depending on years and stakes. State audits are often more aggressive on procedure than federal.
Red flags to watch for when picking a tax / irs lawyer in Albuquerque
The big legal directories list hundreds of Albuquerque attorneys for this work. Most are competent. A few are problematic. Watch for these patterns.
Guaranteed outcomes. No ethical attorney can promise a specific result. If a firm guarantees a court win, a tax debt cut to zero, or a perfect contract that "can never be challenged," walk away.
The disappearing partner. You meet a senior name at the intake meeting, then never speak to that person again. Your file gets handed to an unsupervised junior or a paralegal. Ask in writing who will be your day-to-day attorney and what the supervision structure looks like.
Pressure to sign on the spot. Reputable firms send you the engagement letter, give you time to read it, and let you take it home. Same-day "you have to retain us today" tactics are almost always a sign of a volume mill, not a craftsperson's practice.
No verifiable track record. The firm should be able to point to peer rankings, bar specialization, published case results, or named clients. "We have helped thousands" is marketing copy. Specific case names, transaction sizes, or third-party recognitions are evidence.
Vague fee terms. "Don't worry about cost" is a red flag. Every legitimate Albuquerque lawyer will give you a written engagement letter with the fee structure, what is included, what triggers extra charges, and what happens if you terminate the relationship.
10 questions to ask in your free consultation
Most firms on this list offer a free or low-cost initial consultation. Use it. Bring a written list of questions and write down the answers. Compare across at least two firms before you sign anything.
Who, specifically, will handle my matter day to day? Get a name and an email. Confirm that this person, not the partner you met at intake, will be your primary point of contact.
How many matters like mine have you handled in the last three years? You want a real number, not a brochure line.
What is your fee and what does it cover? Get the answer in writing before you sign. Hourly, flat, contingency, or hybrid — and what triggers a change.
What costs am I responsible for outside the legal fee? Filing fees, expert witnesses, third-party services, courier, transcription. Ask now to avoid surprise invoices.
What is a realistic range of outcomes for a situation like mine? A good lawyer will give you a range with assumptions. A bad one will only describe the best case.
How long will it take? Honest estimate with the assumptions stated. A complex business contract is days. A multi-year IRS audit is years.
Who else might be involved? Co-counsel? Experts? Local counsel? Larger matters routinely involve outside specialists. Know who is on the team and how they bill.
How and how often will I hear from you? Email-only? Weekly calls? Status updates on a schedule? Set the expectation up front.
What happens if I want to change lawyers later? The rules allow it; the fee is sorted between firms. Make sure you understand the mechanics before you commit.
What is the worst case for me here? A lawyer who refuses to discuss downside risk is selling, not advising.
What is specific about a tax / irs matter in Albuquerque
Federal IRS matters in Albuquerque. The IRS Albuquerque field office handles audits, examinations, and appeals for the NM region. U.S. Tax Court cases for NM petitioners are filed in Washington but trial sessions are held in Albuquerque. The Court calendars trial sessions periodically; venue and scheduling matter to how a case is built.
New Mexico Taxation and Revenue Department. The TRD administers gross receipts tax, state income tax, withholding tax, motor vehicle tax, and other NM taxes. The TRD has its own audit, hearing, and appeals process — with deadlines that are unforgiving. Notice deadlines and protest windows are typically 30–90 days; missing them often means losing the right to challenge the assessment.
Gross receipts tax, not sales tax. NM does not have a sales tax. It imposes a gross receipts tax on most business activity, with the seller typically bearing the obligation. GRT rates in Albuquerque run roughly 7.6–8.3 percent depending on zone. Misclassifying a service or mis-sourcing a sale is one of the most common audit findings; the dollars can add up across years quickly.
Statute of limitations. For most IRS issues, the assessment SOL is 3 years from filing; 6 years for 25 percent or more underreported income; unlimited for fraud or no return. For NM TRD, the standard assessment SOL is 3 years from the filing due date, with extensions for fraud and intentional avoidance.
The Notice of Claim deadlines (state). If you have a refund claim against the State or are challenging a state assessment, the protest deadlines are unforgiving. The right attorney files the protest the day the notice arrives, not the day before the deadline.
Frequently asked questions
Do I need a tax attorney or a CPA?
Different jobs. A CPA prepares returns, plans annual tax, and represents you in audits for the years they prepared. A tax attorney handles disputes, appeals, U.S. Tax Court, criminal tax matters, and complex planning. For an audit, an offer in compromise, or a contested IRS issue, you want the tax attorney. Several of the firms above are dual J.D./CPA.
Can the IRS take my house?
Yes — through the levy and lien processes — but it is rare and usually only after months or years of unresolved tax debt. A controversy attorney's job is to keep the matter from reaching that point through installment agreements, offers in compromise, currently-not-collectible status, or appeals.
What is an offer in compromise?
A formal IRS settlement that reduces tax debt below the amount owed. The IRS evaluates based on a defined formula (Reasonable Collection Potential) using your income, expenses, and assets. Roughly 30–40 percent of OICs are accepted nationally; the rate is much higher for cases with strong financial preparation.
How long does an IRS audit typically take in Albuquerque?
A correspondence audit: 3–6 months. A field or office audit: 6–24 months from initial contact to closing. Appeals add 6–18 more months. U.S. Tax Court adds another 12–36 months.
Should I respond to an IRS notice myself?
For a routine notice (CP2000 underreporting, simple math error), often yes — the IRS notice usually has clear instructions. For an audit notice (Letter 2202, 566, or any field exam letter), a CP90/CP504/CP523 levy or collection notice, or any criminal referral, hire an attorney before responding.
What is the New Mexico gross receipts tax?
A tax on most business activity in NM, imposed on the seller of goods or services. Rates vary by location (Albuquerque is roughly 7.6–8.3 percent). The TRD audits regularly; the most common findings are misclassified services, mis-sourced sales, and missing deduction support.
What happens if I cannot pay my IRS debt?
Options include: installment agreement (most common), offer in compromise (if you qualify financially), currently-not-collectible status (temporary), penalty abatement, bankruptcy (limited tax discharge), or innocent spouse relief. A controversy attorney runs the analysis based on your financial reality and picks the right path.
One last thing. Choosing a lawyer is personal. Read the reviews. Call two or three firms before you sign. Ask each one the same opening question: How many matters like mine have you handled in the last three years, and what were the outcomes? The way they answer tells you almost everything. — The LawFirmSquare team
Helpful next steps
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