The Tax Controversy and Litigation Practice deals regularly with the IRS, the Treasury, the Department of Justice, and state taxing authorities in resolving tax disputes and cases. We have successfully handled a wide variety of tax disputes at the federal, state and local tax levels.
Our tax litigation representations include diverse industries involving a wide array of substantive tax issues in the areas of income, estate and gift, excise, and employment tax, as well as in the tax-exempt arena. We many times are required to apply complex provisions of the tax law to facts arising out of highly specialized areas such as transfer pricing, business valuation, complex mergers and acquisitions, corporate finance and real estate. In preparing cases, we work closely with in-house specialists as well as with private sector and academic consultants and expert witnesses. We work in a fully integrated fashion with our clients' in-house counsel and tax directors, and take pride in understanding and achieving our clients' goals in tax disputes. Our Tax Controversy and Litigation Practice’s ability to realistically evaluate litigation hazards has led to extraordinarily favorable settlements for clients at the examination and IRS Appeals levels and in pretrial settlements.
In addition to representing clients in tax litigation, we frequently counsel our clients regarding tax procedures, such as reporting and disclosure requirements, the avoidance or abatement of tax penalties, privileges, summons enforcement, and discovery. We also represent clients involved in criminal tax investigations advising at the entity, senior management, or outside advisor level during the grand jury process, at indictment and post-indictment.