Tax Controversy and Litigation
As former tax attorneys for the IRS, our partners know how to achieve the best outcome possible for you in the event of a tax audit. Effectively managing an audit for a client involves understanding the entire controversy process (audit, administrative appeals process, litigation), the procedural mechanisms that can place the burden of proof on the IRS, and the procedural rules governing IRS personnel at each stage. We possess deep and varied tax expertise throughout the entire tax controversy process from the audit stage, IRS Appeals Office consideration and litigation in court. Some areas of specialized experience include:
Tax Court Litigation Services
- IRS audits and audit reconsideration
- U.S. Tax Court and District Court litigation
- Global high wealth industry audits
- Cannabis industry tax issues
- Promoter and preparer investigations
- Estate and gift tax disputes
- Foreign account disclosure procedures
- Penalty abatement
- Innocent spouse relief
- Criminal investigations
Tax Controversy or Litigation Special Co-Counsel
In certain tax controversy matters or litigation, clients may need special co-counsel who can provide an independent perspective on the tax dispute. Given the large amount in dispute or combativeness that may have developed between the litigants, our tax partners can serve as litigation advisors assessing the merits of both parties’ positions to provide clients with an independent legal perspective on risk so the clients can make informed decisions at each stage of tax controversy.