All companies, organizations and individuals can expect to encounter tax issues. In order to provide our clients with the experience and services they need, Polsinelli Tax attorneys must have either a Master’s in Accounting, be a CPA or have a Master’s in Tax Law. With those qualifications, Polsinelli Tax practice attorneys provide creative solutions and legal guidance on international, federal, state and local tax laws to entities in all major industries and tax status classifications. Our attorneys partner with clients to develop business solutions related to:

Polsinelli Tax practice attorneys’ strong reputation is built on sound and effective planning, in-depth analysis and favorable resolutions and outcomes, particularly in complex tax matters involving diverse businesses. We are innovative and have vast experience in structuring business formation, combinations, reorganizations, mergers and acquisitions, and liquidations in the most tax-advantageous manner. If needed, the Polsinelli Tax Practice attorneys’ litigation experience spans all judicial forums, including the U.S. Tax Court, federal courts, state courts and administrative tribunals throughout the country. 

Polsinelli Tax Practice attorneys’ experience and sound judgment provide clients with appropriately assessed tax risks with the potential benefits of a judicial or administrative resolution of the issue. Polsinelli Tax attorneys bring both Certified Public Accountant (CPA) and advanced legal qualifications to tax advising (including LLMs) for individuals and businesses. Offering both extensive tax planning and tax audit and appeal services, we represent our clients’ interests in preserving income and protecting assets.

With offices located coast-to-coast, Polsinelli’s Tax attorneys are also equipped to represent clients regarding local, county and state tax issues for employment and independent contracting, partnerships and LLC structuring, audits and tax controversies across the United States. The Polsinelli Tax practice is experienced in handling the following issues:

  • Income tax
  • Sales and use tax
  • Excise tax
  • Property tax

Our team is well-versed in all kinds of tax controversies that can arise and we are prepared to take appeals to state tax appeal tribunals and appellate courts. Clients who work with us know that our Tax attorneys are skilled at communicating highly technical areas of the law, making it easy for clients to understand. This talent sets us apart from many of the professionals practicing in the tax industry.

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Clock Beats Commissioner: IRS Concedes $48M Easement Case
Key Takeaways On March 23, 2026, the U.S. Tax Court entered a stipulated decision in Agate Holdings LLC, Agate Manager LLC v. Commissioner under which the IRS conceded the partnership’s full $48.3 million deduction for a Louisiana conservation easement donation. The decision provides that accuracy-related penalties and civil fraud penalties do not apply for the 2018 tax year. According to the reported stipulation, the IRS’s concession was based solely on the fact that its Nov. 3, 2023 notice was not timely issued under Internal Revenue Code Section 6235. This development is significant because it highlights how procedural issues can be outcome-determinative in conservation easement cases. The taxpayer had accused the IRS of backdating documents to support otherwise time-barred penalties and adjustments, but the stipulated
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A Win on Fraud, a Warning on Valuation: Takeaways from North Donald
On February 19, 2026, the U.S. Tax Court issued its opinion in North Donald LA Property, LLC v. Commissioner (T.C. Memo. 2026-19), a syndicated conservation easement (SCE) case involving an asserted 75% civil fraud penalty and, alternatively, accuracy-related penalties. Key Takeaways The IRS did not meet its heavy burden to prove civil fraud by clear and convincing evidence and there was thus no fraud penalty (75%). The 40% gross valuation misstatement penalty was imposed due to significant overstatement of the value claimed on the return. While the 40% penalty was a meaningful improvement on the penalty front, it is still a very high penalty compared to many recent IRS settlement resolutions currently being offered by the SCE space. The Opinion Broken Down Key takeaway: no fraud
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