tax controversy

A significant portion of our tax practice involves representation before the Internal Revenue Service, and state and local tax authorities in resolving tax disputes at various administrative levels. Our attorneys assist clients with tax audits and with protests and appeals. We also assist clients in connection with refund claims, and matters pertaining generally to collection, levy, payment and compliance. Whenever possible we attempt to resolve disputes administratively prior to litigation and obtain rulings from the IRS and state tax authorities where appropriate.

We work in a fully integrated fashion with our clients' in-house tax personnel, and take pride in understanding and achieving our clients' goals in tax disputes.

Our ability to realistically evaluate litigation hazards has led to favorable settlements. When settlement cannot be reached, we litigate in the U.S. Tax Court, federal district and appeals courts, the U.S. Court of Federal Claims, and their state and local counterparts. Our tax litigation has involved clients in diverse industries involving a wide array of domestic and international tax issues arising from corporate and individual income, estate, gift, excise and employment taxes, as well as issues of tax exempt organizations. In preparing cases, we work closely with in-house specialists, as well as with private sector and academic consultants, including expert witnesses.