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TAX CONTROVERSY

Our tax controversy attorneys are true tax litigators who combine substantive knowledge and experience in tax law with a keen understanding of your business. Whether we work with you from the outset of a controversy or after initial attempts at resolution have failed, our objective is to resolve your tax dispute efficiently and in a manner aligned with your objectives.

The Experience You Need When the Stakes are High

We effectively resolve federal tax disputes with the IRS. We advise and represent a diverse client base including public and privately held corporations, partnerships, limited liability companies, high-net-worth individuals, and trusts and estates at all levels of administrative tax controversy and in litigation. We also represent clients in all phases of the controversy and litigation process at the state and local level. 

Our well-regarded team includes former IRS senior trial attorneys, IRS Office of Chief Counsel and Department of Treasury advisors, Tax Court clerks and a former Joint Committee legislation counsel. Our team’s in-depth knowledge of administrative tax law and procedure, as well as the strong relationships we maintain with the IRS and the Treasury department, significantly enhance our team’s ability to resolve even the most entrenched tax disputes.

We work with you at all stages of the controversy from audit, to the preparation of tax protests and negotiation with IRS Appeals, to litigation in United States Tax Court, the Federal District Courts, the Court of Federal Claims and the United States Supreme Court:

  • We work closely with you to understand your definition of “success” and collaborate with you to pursue those outcomes.
  • We shepherd the controversy through the administrative appeals process, including using alternative dispute resolution techniques and tools such as Early Referral, Rapid Appeals Process, Fast Track Settlement and Post-Appeals Mediation.
  • When litigation is unavoidable, we will design strategic approaches to selecting the forum, developing supporting facts, incorporating industry-specific themes, selecting and using expert witnesses, and maximizing the effectiveness of traditional and e-discovery techniques.