Tax Controversy
We represent taxpayers at all levels of civil tax controversies from the IRS Appeals Division to the United States Tax Court in deficiency proceedings or Federal District Court in refund claims and trust fund liabilities. Our experience in tax controversies includes but is not limited to tax shelter/sham transaction defense, section 29 energy credits, promoter penalties, civil tax fraud, trust fund liabilities, passive loss limitations, excise tax controversies, as well as various other business tax disputes with the Internal Revenue Service. We also have extensive experience representing taxpayers targeted for criminal prosecution either as an IRS administrative investigation or grand jury investigation.
