Tax Controversy

When representing you in contested tax matters, our goal is to achieve resolution as early as possible while meeting your business objectives. If, however, the taxing authorities do not allow administrative resolution of issues, we will seek to obtain judicial relief in the federal and state courts.

During the audit process, we assist clients on significant, complex issues that require special care in presenting the facts and law to the IRS, including:

• Negotiating the scope of the audit
• Formulating responses to information document requests
• Responding to and contesting summonses and notices of intent to levy or federal tax liens
• Obtaining pre-filing agreements and technical advice memoranda
• Negotiating and finalizing tax closing agreements

Our scope working with IRS appeals offices covers virtually every taxpayer contested issue, including complex international, corporate and partnership issues, employee benefits tax issues, and criminal tax investigations and tax fraud matters. In addition to traditional appeals negotiations, we are experienced with alternative dispute resolution programs, such as the Fast Track Settlement program, Post-Appeals Mediation program, and other types of mediation and arbitration. We also have significant experience in the Tax Court, Court of Federal Claims, various U.S. District and state and local courts and the Circuit Courts of Appeals, where our experience and knowledge of substantive and procedural matters allows us to achieve optimal results for our clients in a cost-efficient manner.

We have represented clients in a wide range of tax controversy matters, including those related to:

• Tax-free reorganizations
• Partnership
• Financial products
• Foreign tax credit
• Transfer pricing
• Intangible assets
• Conduit issues
• Debt/equity issues
• Capitalization
• Inventories
• Accounting methods
• Tax-advantaged transactions
• Discovery, privilege and other procedural issues
• Worker classification issues
• Hobby losses