Overview
Federal Tax Controversy
We can help you resolve complex tax disputes with the Internal Revenue Service (IRS), approaching each engagement with a strategic plan that will benefit you for the tax year in dispute—and in future tax years. We partner closely with you to understand your business goals and help you efficiently achieve your objectives.
To position you for success at any stage of a dispute, we draw on decades of experience representing people and businesses in IRS audits (including in the IRS’s Compliance Assurance Process), IRS administrative appeals, and litigation in federal trial and appellate courts. While we resolve most tax disputes at the IRS audit and IRS administrative appeals level, when settlement is not possible, we have a successful track record of litigating tax disputes in federal court.
We have resolved numerous matters through the IRS’s alternative dispute resolution procedures, including Industry Issue Resolution, Fast Track Settlement, Early Referral to Appeals, Rapid Appeals Process and Post-Appeals Mediation. We also have substantial experience with international tax disputes and transfer pricing issues, including navigating complex domestic and foreign-initiated competent authority cases (Mutual Agreement Procedure), and seeking and negotiating Advance Pricing Agreements.
IRS Audits
When you are under IRS audit, you need a legal team that understands how the IRS thinks and recognizes when the IRS is stepping outside of established rules and procedures. We have developed that understanding through experience advising clients in negotiating and responding to Information Document Requests (IDRs), maintaining privilege, developing audit strategies, and interacting with IRS audit personnel.
Each audit has its own nuances, and our work on your audit may involve behind-the-scenes advice or directly interfacing with the IRS exam team. Our level and manner of involvement is strategic, and we handle each audit as one part of a holistic approach to a federal tax controversy.
IRS Appeals
Because we spend a significant amount of time advocating for our clients before the IRS Independent Office of Appeals, we know how to settle cases with IRS Appeals—typically by getting creative and “thinking outside the box.” We employ that experience and strategic vision to settle your matter for the best possible outcome.
Federal Tax Litigation
Sometimes the only place you can resolve a complex federal tax matter is in court. We use our substantial experience litigating all types of federal tax matters in court to help you navigate the process and achieve a favorable outcome. Our ability to handle a case from the start of the audit through litigation and court appeal gives us a unique, long-range perspective that benefits you and sets us apart from other tax controversy groups.
We have litigated some of the largest and most complex tax cases in US history, achieving tremendous results in all types of tax matters in federal courts. Our team has litigated dozens of “bet-the-company” cases, tax issues of first impression and complex, technical cases that have resulted in favorable settlements, 100% government concessions and taxpayer court victories. We have also successfully represented our clients in summons enforcement proceedings and disclosure actions, and we have extensive experience challenging the validity of tax regulations and advancing arguments under the Administrative Procedure Act.
We regularly litigate tax matters before the US Tax Court, US Federal District Courts, the US Court of Federal Claims, US Circuit Courts of Appeal and in the US Supreme Court.
Pro Bono Work
Part of our philosophy is to give back to our community, and our team is active in representing low-income taxpayers on a pro bono basis in litigation. We have handled dozens of cases resulting in opinions on issues of first impression on innocent spouse and penalty issues, providing relief to low-income taxpayers nationwide.
