Tax Controversy

Our experienced tax attorneys represent clients in all aspects of federal, state, and local income taxation and tax disputes, including estate and gift, employment, and other tax disputes. They’ve resolved hundreds of issues in the aggregate of several billion dollars and provided consulting and expert witness services on a wide range of tax matters.

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    What We

    Strategic Audit Planning

    We help our clients formulate audit strategies and effectively deal with the IRS and other taxing authorities to resolve issues as quickly as possible.

    LB&I Expertise

    We have extensive experience representing large multinational corporations (both public and private), subject to the IRS’ Large Business and International coordinated examination program.

    Trial Services

    When administrative settlements do not achieve the desired outcome, we bring in a team of seasoned litigators with the experience to deliver the right results for our clients.

    Expert Witness & Consulting

    Our services include representation in case evaluation, risk assessment, case development, trial preparation, and expert witness testimony on tax related topics.

    Landmark Matters

    Practice Area: Tax Controversy
    Industry: Expert Services
    Regularly served as expert witness in public trials and arbitration proceedings involving tax-related matters, including tax planning, return preparation, and accounting and legal malpractice.
    Practice Area: Tax Controversy
    Industry: Individual Taxpayer
    Represented taxpayer before IRS with respect to audit of constructive dividend adjustments, resulting in full IRS concession.
    Practice Area: Tax Controversy
    Industry: Individual Taxpayer
    Represented boxing champion in IRS Appeals regarding audit of substantial loss deductions, achieving full concession of the asserted deficiency.
    Practice Area: Tax Controversy
    Industry: Information Technology
    Represented corporate taxpayer in IRS Appeals in achieving successful settlement of material issues involving excess loss account adjustments, capitalization issues, deductibility of investment banking fees, and asserted negligence and substantial understatement penalties.
    Practice Area: Tax Controversy
    Industry: Manufacturing
    Successfully mediated IRS appeal dispute on behalf of corporate taxpayer regarding $100 million worthless stock and "bed debt deductions."
    Practice Area: Tax Controversy
    Industry: Finance and Investments
    Represented corporate taxpayer in successfully defending against IRS challenge to deductibility of several hundred million dollar settlement payment arising out of financial institution failure.

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