Previous Law Firm Name

• Pridgeon Law Office

Law Firm Overview

Our firm handles legal matters in the following practice areas: Taxpayer Representation, Tax Litigation, and Tax Consulting. Our primary focus involves resolving tax disputes with the Internal Revenue Service, the Minnesota Department of Revenue and the Minnesota Department of Employment and Economic Development. Our work on behalf of taxpayers ranges from representing taxpayers in the courts including the United States Tax Court, United States District Court, Eighth Circuit Court of Appeals, and the Minnesota Courts, including the Minnesota Tax Court and the Minnesota Supreme Court. We have also represented taxpayers in administrative hearings before the Minnesota Department of Employment and Economic Development. Of course, a court room trial is the last resort after all attempts to resolve a tax dispute through negotiation have failed. The vast majority of tax disputes can be resolved without resort to a court room trial. The attorney for this law firm is Mark A. Pridgeon. His qualifications and experience are set forth on the Attorney's page. To briefly summarize, he has practiced as an attorney for the Chief Counsel's Office of the Internal Revenue Service, worked as a senior manager in two large accounting firms and represented taxpayers with tax difficulties since 1990. In 1992, Saree Olson joined the firm as a paralegal, legal secretary and office administrator. She has worked with clients on countless financial statements for Offers in Compromise, Installment Agreements, and also works with Mark on litigation and appeals.

Areas of Practice

• Taxation Law
• Appeals from Audits, Commissioner's Orders and Other Actions of Tax Authority
• Applications for Certificate of Discharge, Release and Subordination of Tax Lien
• Audits
• Collection Due Process Appeals
• Dischargability of Taxes in Bankruptcy
• Employment Taxes
• Freedom of Information Act Requests (FOIA)
• Independent Contractors v. Employee Determinations (Conflicts with the Minnesota
• Department of Employment and Economic Development)
• Innocent Spouse/Injured Spouse
• Installment Agreements
• Installment Payment Plans
• Officer Liability for Unpaid Sales, Employment and Unemployment Taxes
• Offer in Compromise
• Refund Claims and Suits for Refunds
• Requests for Abatements of Tax, Interest and Penalties
• Sales & Use Taxes
• Seizures & Sales by the Tax Authorities
• Successor Liability
• Tax Levies
• Tax Liens
• Tax Litigation, Federal and State Courts
• Trust Fund Recovery Penalties

Published Works

• When Is A Penalty Not A Penalty: Internal Revenue Service Trust Fund Recovery Assessments, MNCPA Footnote Magazine, 1995
• IRS Survival Guidelines: New Rules on Installment Payment Agreements, MNCPA Footnote Magazine, 1996
• Penalty, 1996
• Penalty, 1994

Classes and Seminars

• Adjunct Professor, Master of Business in Taxation Program, University of Minnesota, 1989 - 1992
• Speaker, Internal Revenue Service Collection Procedures, 1993
• Speaker, Representing A Taxpayer During An IRS Audit, 1993
• Speaker, 100% Payroll Tax Penalty: Who Can Be Held Responsible, MNCPA, 1995
• Speaker, Internal Revenue Service Audit Developments, MNCPA Annual Tax Conference, 1995
• Speaker, Internal Revenue Service Collection Procedures, MEGA Conference, May 30, 1996
• Speaker, How to Handle a Case in Tax Court (Federal and State) Taxpayer's Attorney's Perspective, Minnesota Institute for Legal Education (MILE), 1996
• Speaker, Internal Revenue Service Collection Procedures, Current Audits and One Hundred Percent Penalties by Mark Pridgeon and Saul Bernick, MNCPA Annual Tax Conference, 1996
• Speaker, Handling A Criminal Investigation Division Investigation, Hennepin County Bar Association, November 8, 1999
• Speaker, Ten Classic Court Cases With Lasting Impact, 1999
• Speaker, Tax Law Changes, 1999
• Speaker, Recent Developments in Federal Tax Controversies, Hennepin County Bar Association, September 11, 2000
• Speaker, Representing Your Clients With Tax Controversies Before the Tax Authorities, MSBA's 60th Annual Tax Institute, November 14, 2000
• Speaker, You Said Avoidance, I Say Evasion... Issues in Criminal Tax, MSBA's 61st Annual Tax Institute, November 12, 2001
• Speaker, Recent Developments in Federal Tax Controversies, Hennepin County Bar Association, October 13, 2003
• Speaker, Tax Developments, Jim Stanko, Honeywell, February 23, 1999

West Practice Categories

Bankruptcy Law, Business & Commercial Law, Business Organizations, Collections, Freedom of Information, Employment Law -- Employee, Employment Law -- Employer, Labor Law, Litigation & Appeals, Tax Litigation, Real Estate Law, Taxation Law