Tax Controversy Attorneys | McDermott Tax Litigators

Tax Controversies

Overview


As tax laws evolve and the focus on enforcement increases, so do the risks and challenges you face. To strategize and stay ahead of potential tax controversies, you need forward-thinking legal counsel.

With one of the largest tax practices in the US, along with first-rate tax practitioners in our offices around the globe, we can provide you with the nuanced resources and experience you need to handle any tax controversy, at any stage, with any type of taxing authority—in or out of the courtroom.

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Results


  • Secured a complete victory on all issues in a major US Tax Court case, Illinois Tool Works Inc. v. Commissioner of Internal Revenue Service. The high-profile case, in which the IRS challenged the repatriation strategy and determined that Illinois Tool Works was liable for more than $84 million in income tax deficiency and penalties, was presented before the United States Tax Court and the court resolved all issues in Illinois Tool Works’ favor. The decision, which had been highly anticipated and garnered extensive press coverage in the tax community, came after an eight-day trial in July 2016 and multiple briefings.
  • Served as lead tax litigation counsel for a $3 billion estate with respect to an alleged $150 million estate and gift tax deficiency involving transfer of interests in a professional sports team, building consensus among tax litigation counsel employed by three sets of beneficiaries adverse to each other in pending probate litigation and advising the court-appointed personal representative regarding his fiduciary duties.
  • Won U.S. Supreme Court case on statute of limitations issue with aggregate tax at issue of more than $1 billion; Home Concrete & Supply.
  • Achieved Fast Track Settlement that resolved multi-billion dollar proposed adjustments for several years under Subpart F and complete abatement of 20% accuracy-related penalty in excess of $1 billion.
  • Obtained 95% IRS concession on Code section 162(f) issue related to claimed deductions of several hundred million dollars.

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People


A diverse, global network of industry-leading talent committed to you and your vision.

Key Contacts


Jenny L. Johnson

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