Denise M. Mudigere focuses her practice on representing individuals and entities in all stages of federal civil and criminal tax controversies. She represents clients in US Internal Revenue Service (IRS) examinations, administrative appeals, and litigation. Denise has settled multiple tax disputes in administrative proceedings and with IRS legal counsel—avoiding litigation in court, when possible.
Representing multinational company in IRS administrative proceedings in connection with IRS attempts to reclassify debt as equity
Representing a multinational company in connection with an IRS examination of tax issues related to the takeover of a publicly traded company and the subsequent restructuring of its stock acquisition
Representing a large multinational company in summons enforcement litigation regarding the company’s assertion of privilege for tax advice given during high-stakes refinancing and restructuring transactions, including appellate briefing and coordination of international privilege review efforts; Second Circuit opinion affirmed taxpayer’s position and set favorable precedent for protection of tax and business advice
Representing taxpayers in Tax Court litigation in connection with IRS efforts to convert private equity and hedge fund capital gains into ordinary income
Successfully negotiated settlements for numerous US taxpayers in connection with IRS challenges to losses arising from investments in distressed assets
Obtained a favorable Tax Court ruling on all issues for former shareholders in litigation involving the IRS’s determination of transferee liability arising from the sale of a family business
Successfully defended against accuracy-related penalties and raised a reasonable cause defense in Tax Court for taxpayer that acted reasonably and in good faith in deducting losses the IRS challenged
Assisted a major corporation in an accurate assessment of potential federal and state successor liability taxes related to the corporation’s initial acquisition of certain assets and a pending merger agreement; successfully negotiated with taxing authorities to cancel successor liability and release all liens and levies
Successfully negotiated a settlement of under $50,000 for a taxpayer in an administrative appeals mediation regarding an IRS challenge of the taxpayer’s net operating loss deductions, with more than $14 million at issue
Assisted a foreign federal government in drafting fair tax collection legislation
Assisted a testifying expert witness on tax litigation procedure, trial strategy, and ethics in connection with a confidential arbitration arising out of the high-profile Long Term Capital Holdings case
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