Tax Controversies & Litigation

Avoiding tax controversy is a shared goal among high-net-worth individuals, corporations, and nonprofit organizations alike. But disputes will arise. Whether the issues are at the federal, state, or local level, businesses and individuals need a steady hand to guide them along the path toward resolution.

HOW WE HELP

Our attorneys navigate the maze of potential audits, administrative appeals, and litigation for entities large and small. Because of our strong working relationships with high-level personnel at the Internal Revenue Service, as well as state and local taxing authorities, our team has the answers clients need and the means to resolve misunderstandings quickly. Tax-exempt entities in particular turn to our attorneys for their unrelated business income, excise and property tax audits, appeals and other forms of alternative dispute resolution, and litigation when necessary, including proposed revocations of tax-exempt status.

OUR SERVICES

Our attorneys make sure our clients are on the front foot managing exposure at every turn, whether this means proactively disclosing information, working toward a settlement, or minimizing losses.

Audits. When audits happen, you need the right people on your side. Our team works with clients to formulate audit and examination strategies aimed at mitigating future risks and, whenever possible, settling cases quickly—with minimal disruption to business operations.

Administrative Appeals. Should a dispute escalate, our attorneys have a stellar track record of reducing penalties and asserted deficiencies. When issues cannot be resolved at the audit level, our team deftly navigates settlement conferences, appeals, and other administrative procedures to secure favorable results. The team is also skilled at using binding and non-binding arbitration and mediation procedures as a means of resolving cases without trial.

Litigation. When the audit and appeals processes have been exhausted and litigation is inevitable, our attorneys represent clients in jury and non-jury trials, and appeals to federal and state appellate courts. Our success record in state and federal trial and appellate courts speaks for itself in the US Tax Court, the US Court of Federal Claims, and various federal district courts.

THE SEYFARTH EXPERIENCE

Our team pools knowledge from colleagues in Seyfarth’s corporate, real estate, labor and employment, and employee benefits to provide tailored solutions to clients’ diverse and ever-changing tax controversy needs.

Members of our tax team lead the school of thought on many complex taxation topics and have authored treatises that serve as the sole reference authority in US tax law. Several of our attorneys clerked for the US Tax Court, while another previously served with the Tax Division of the US Department of Justice.