Practice Areas

Powers Marion is a boutique tax firm focused on tax audits and administrative appeals. We represent individuals, businesses, partnerships, and estates in disputes with federal and state taxing authorities, including the Internal Revenue Service Examination Division and Appeals Office. We develop strategic audit responses, manage communications with government agents, and handle all aspects of the administrative process—from initial examination through appeal. With experience in complex and sensitive matters, Powers Marion is positioned to resolve disputes efficiently while preparing cases for further proceedings when necessary.

We work to resolve disputes efficiently when possible but are fully prepared to litigate through trial and appeal. Representing clients at both the federal and state levels, including proceedings in U.S. Tax Court, federal district courts, and state courts, we approach litigation with a deep understanding of tax law, procedural strategy, and evidentiary development. Whether the matter involves complex corporate structures, high-value transactions, or sensitive financial issues, the goal is to present a credible case that withstands scrutiny and advances the client’s position at every stage.

We represent individuals and entities in criminal tax investigations and prosecutions, including matters involving unreported income, improper deductions, failure to file, and alleged false statements.  Our goal is to avoid indictment whenever possible, and early involvement allows for strategic engagement with the government and, in many cases, resolution without criminal charges. When prosecution cannot be avoided, Powers Marion provides experienced, trial-ready defense through every stage of the process, including plea negotiations, trial, and sentencing.  With a combination of deep tax knowledge and criminal defense experience, we deliver strategic representation in high-stakes matters.

If you or your company is facing an audit or investigation for employment tax, we can help. Employers must withhold and remit employment taxes, and enforcement activity by the government has increasingly targeted this area through audits and criminal investigations, with particular attention to worker classification, unpaid employment taxes, non-filers, and officer compensation. Determining whether a worker is an employee or an independent contractor depends on the degree of control over how the work is performed and the surrounding working relationship, and misclassification can lead to significant consequences, including back taxes, interest, penalties, and potential issues with employee benefit plans for employers, as well as additional tax liability and loss of deductions for workers. In addition, individuals within a business who are responsible for collecting and paying employment taxes can be held personally liable if those taxes are not paid, particularly where there is a conscious decision to use available funds to pay other obligations instead of satisfying tax liabilities; this responsibility is determined by actual authority and control over financial decisions rather than formal titles.  The IRS offers a voluntary program that allows eligible taxpayers to reclassify workers going forward with partial relief from past employment tax exposure.

When tax liabilities become subject to collection, the consequences can be immediate and disruptive. We represent clients facing IRS and state collection actions, including liens, levies, and wage garnishments. We work to stabilize the situation quickly, protect assets where possible, and pursue resolution through available mechanisms such as installment agreements, offers in compromise, and collection due process proceedings. Each matter is approached with a focus on practical outcomes and long-term financial stability.

Usually when a government examiner finds a tax deficiency, they have an obligation to evaluate penalties for both the taxpayer and the return preparer.  We assist clients in seeking abatement of penalties based on reasonable cause, administrative relief programs, and other available grounds.

We advise nonprofit organizations on qualification, compliance, and operational issues related to tax-exempt status, including guidance on formation, governance, unrelated business income, and regulatory obligations. In addition, we represent exempt organizations in audits and disputes with taxing authorities, helping protect their status and ensure continued compliance with complex and evolving rules.

Our team offers exceptional representation in Alabama tax matters, led by Glenmore P. Powers II, a former Deputy Attorney General and Director of Investigations for the Alabama Department of Revenue. With over 20 years of tax law experience, Glen authored the Alabama Tax Fraud Manual and directed complex criminal tax investigations. His years in both government and private practice provide him with a unique, insider perspective on state tax enforcement, enabling us to navigate even the most challenging tax issues with precision.

For taxpayers with undisclosed liabilities or compliance issues, voluntary disclosure can reduce potential penalties and criminal exposure. We advise on federal and state disclosure programs and manage the process from evaluation through resolution. These matters require careful handling and a clear understanding of enforcement priorities to achieve the best available outcome.

We represent clients in securities investigations and enforcement actions involving alleged violations of federal and state securities laws, including matters with parallel civil and criminal exposure. These cases often involve complex financial transactions and significant regulatory and reputational risk. With extensive experience in enforcement and litigation, we provide practical, experienced counsel aimed at protecting our clients’ interests and guiding them through technical regulatory proceedings.

Healthcare fraud investigations often involve overlapping regulatory, civil, and criminal exposure. We represent healthcare providers and related entities in federal and state investigations and enforcement actions. With years of criminal defense experience, we understand how these matters develop and how quickly they can escalate. We focus on responding effectively to government inquiries, managing risk, and addressing both the legal and operational realities clients face in a heavily regulated environment.

We serve as co-counsel to other law firms in complex tax and white collar matters, providing focused experience in tax controversy, financial investigations, and government enforcement actions. This includes supporting litigation teams, advising on tax-sensitive issues, and assisting in investigations at both the state and federal level. We work within existing client relationships and integrate seamlessly with trial and advisory teams to provide practical input at every stage of a matter.

When potential misconduct arises, organizations must respond quickly and carefully. We conduct internal investigations involving tax, financial, and regulatory issues to establish the facts and assess potential exposure. Our approach emphasizes independence, discretion, and thorough analysis. When necessary, we also advise on disclosure obligations, remediation measures, and interactions with government authorities.