Our tax controversy professionals have significant experience representing clients in tax disputes at the audit and appeals levels of the IRS and state and local tax authorities, as well as before the IRS National Office, Treasury Department, Tax Court, and other federal and state courts. Some of our professionals previously worked for the IRS Office of Chief Counsel and the U.S. Department of Justice, bringing valuable insider experience to our practice.
We aim to resolve tax-related disputes quickly and effectively, drawing on our extensive experience in all aspects of tax examinations, administrative appeals, and civil and criminal tax controversies. When federal and state tax authorities fail to respond to earnest negotiations or testimony in hearings, we deploy our experienced tax litigators at trial and in every level of the appellate process.
Our services include:
- Negotiating the scope of audits;
- Formulating responses to information document requests;
- Responding to and contesting summonses and notices of intent to levy or federal tax liens;
- Obtaining pre-filing agreements and technical advice memoranda; and
- Negotiating and finalizing tax closing agreements.
We handle virtually every taxpayer-contested issue, including complex international, corporate, and partnership issues, employee benefits tax issues, and criminal tax investigations and tax fraud matters. We are experienced with alternative dispute resolution programs, such as the Fast Track Settlement program, Post-Appeals Mediation program, and other types of mediation and arbitration.
Our trial attorneys have extensive experience framing arguments to achieve the most favorable results. We regularly represent clients in cases heard before the U.S. Tax Court, the Court of Federal Claims, federal district courts, and various state and local tribunals. We also handle appeals arising from these and other venues.