Tax Controversies and Litigation
Our planning and transactional practices seek to minimize the risk of controversy with the Internal Revenue Service and with state and local taxing authorities.
Where appropriate and feasible, we obtain private letter rulings or technical advice memoranda from the relevant taxing authorities. When a controversy arises, we represent our clients in administrative proceedings at the audit and appeals levels, and have successfully negotiated settlements that eliminate penalties and that eliminate or substantially reduce asserted deficiencies. If an acceptable settlement cannot be reached, we represent our clients in litigation to prevent the imposition of taxes or obtain a refund of taxes paid.