Tax Controversy

iptgears
We have extensive experience working on tax controversy issues at the IRS Examination and Appeals levels, as well as in tax litigation, and on state tax controversy matters.

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Our clients look to us to resolve tax controversy issues at the IRS Examination and Appeals levels, as well as in tax litigation, and on state tax controversy matters. We actively represent clients who are under examination in connection with regular IRS examinations as well as tax shelter matters, and represent taxpayers in appeals before the IRS. We provide ongoing advice to numerous clients who are under continuous examination; this work involves negotiation, planning and analysis of the tax effects of settlements in prior and future years.

We regularly advise clients on ongoing transfer pricing matters and supervise the preparation under attorney-client privilege of supporting documentation by leading independent economists for use as appropriate in audits. We have been successful in achieving out-of-court resolutions of transfer pricing controversies.

We regularly represent clients in the U.S. District Court, U.S. Tax Court and U.S. Court of Federal Claims on tax litigation matters, including corporate, partnership and individual federal income tax issues.

We also represent tax-exempt bond borrowers, issuers and purchasers before the Internal Revenue Service in connection with examinations, closing agreements and before the Department of Justice in responding to IRS summons.