Tax Controversy and Litigation
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 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.
Represented taxpayer in criminal worker classification case in the Northern District of Georgia. The jury acquitted the taxpayer of all tax charges.
Recently tried conservation easement case involving a charitable contribution deduction on the donation of 500 acres along five miles of navigable water near the Atlantic Ocean. Decision pending in the United States Tax Court.
Recently tried conservation easement case involving the disallowance of a charitable contribution deduction on the donation of a golf course to a conservation easement. Decision pending in the United States Tax Court.
Represented retired NFL football player in case where the IRS denied a theft loss the taxpayer suffered when his licensed investment adviser misappropriated $1,679,500 of his funds. Decision pending in the United States Tax Court.