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    Overview

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    Locke Lord's tax controversy practice includes the representation of clients in tax controversies involving the IRS, state, local and foreign governments. We have significant experience resolving our clients' tax controversies at the audit and appeals levels of the IRS, the IRS National Office, the Treasury Department, the Tax Court and other federal courts, and state and local taxing authorities. Our goal in representing our clients in contested tax matters is to resolve matters as early in the process as possible in a manner that achieves the objectives of our clients. However, when taxing authorities do not allow administrative resolution of issues, we obtain judicial relief for our clients in the federal and state courts.

    During the audit process, we assist our clients in connection with significant, complex issues that require special care in presenting the facts and law to the IRS. Our work often includes negotiating the scope of the audit, formulating responses to information document requests, responding to and contesting summonses, and obtaining pre-filing agreements, private letter rulings and technical advice memoranda.

    We also regularly present, negotiate and resolve large, complex cases with IRS appeals offices. The scope of our appeals practices covers virtually every taxpayer contested issue from complex international, corporate and partnership issues to employee benefit taxes and employee vs independent contractor issues. In addition to traditional appeals negotiations, our lawyers are experienced with alternative dispute resolution programs such as the Fast Track Settlement program, mediation and arbitration.

    Our lawyers also have significant experience representing clients in all available courts, including the Tax Court, the Court of Federal Claims, various U.S. District Courts, and Circuit Courts of Appeals. Our experience with and knowledge of substantive, procedural and evidentiary rules enables us to achieve optimal results for our clients in a cost efficient manner.

    Locke Lord has a proven track record of handling complex, high risk tax controversy matters for clients. Our lawyers have also represented clients in a wide range of tax controversy matters including, but not limited to, tax-free reorganizations, partnership, financial products, foreign tax credit, transfer pricing, intangible assets, conduit issues, debt-equity, capitalization, inventories, accounting methods, tax-advantaged transactions, and numerous discovery, privilege and other procedural issues.
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