Taxation and Wealth Planning

Tax Controversy and Litigation

Services

Representation Before the Internal Revenue Service
We work regularly with the IRS to help clients address and resolve issues relating to federal, state and local tax collection matters. We also represent clients in criminal tax investigations and prosecutions and assist clients and their accountants, in the audit process.

We file tax appeals on behalf of clients with the IRS Appeals Division and District Counsel and file actions in the U.S. Tax Court, U.S. District Court, federal bankruptcy courts and Court of Federal Claims. We also handle a variety of IRS collection matters for clients, including but not limited to negotiating payment agreements; preparing and filing offers in compromise; innocent spouse appeals; requesting penalty abatements; discharge or subordination of federal tax liens; and handling trust fund recovery penalty appeals.

Representation Before State and Local Tax Authorities
With office locations nationwide, we can assist clients in a number of venues with controversies involving corporate net income tax, corporate business tax, gross income tax, business privilege tax, wage tax, net profits tax, business use and occupancy tax, capital stock/franchise tax, personal income tax, sales and use tax, realty transfer tax, inheritance tax, estate tax, mercantile tax, earned income tax, amusement tax and fuel tax, among others. We strive where possible to negotiate an amicable administrative settlement that forgoes the need to litigate the underlying issue.