We represent clients in federal and state tax controversies, which include 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, alleged civil tax fraud, tax shelter/alleged sham transaction defense, Section 29 energy credits, promoter penalties, 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 in IRS administrative investigations or grand jury investigations.





