Tax Controversy and Litigation

Overview

We represent clients in tax controversy matters before all divisions and levels of the IRS; the United States Tax Court, District Courts and Courts of Appeal; state departments of revenue and state trial courts; and foreign tax tribunals. In most cases, we are able to resolve matters through negotiation and early-stage contact with tax authorities, including responding to Information and Document Requests (IDRs), appearing on behalf of clients before the tax authority and filing administrative appeals. Rarely do cases advance to the litigation, but in those instances where matters cannot be resolved short of trial we have an experienced courtroom tax team that represents clients aggressively.

Our tax controversy experience includes:

  • Civil tax fraud,
  • Criminal prosecutions,
  • Excise tax controversies,
  • Passive loss limitations,
  • Promoter penalties,
  • Refund claims,
  • Energy credits,
  • Conservation easements,
  • Family limited partnerships,
  • Tax shelter and sham transaction defense,
  • Offshore entity and financial account penalties, 
  • Trust fund tax liabilities, and
  • Challenges to non-profit exempt status.

Experience

Experience

Newsroom

Videos

Video thumbnail of Litigation Fundamentals with Henry Quillian and Donald Boyle | Recent Developments in the Taxation of Settlement Payments

Henry M. Quillian III and Donald P. Boyle Jr. discuss the topic, "Recent Developments in the Taxation of Settlement Payments."

Video thumbnail of Litigation Fundamentals | Recent Developments in the Taxation of Settlement Payments

In this Litigation Fundamentals with Henry M. Quillian IIIJulian A. Fortuna speaks on the taxability of litigation outcomes.

Attorneys

×
media_files/video/HQ_LitFundamentals_092017.mp4
×
media_files/video/TE_LitigationFundamentals_160616_v2.mp4