Our work includes tax audit and dispute resolution proceedings regarding all types of federal taxes before the IRS, the Tax Court, the Claims Court, and other federal trial and appellate courts.
We work closely with company management to formulate an audit strategy prior to filing a tax return for the relevant tax year to avoid imposition of the substantial understatement penalty. We also act as special tax counsel in audit and litigation matters. When we are retained after an audit has been completed, our approach to tax controversies is to consider all of the possible opportunities to achieve the most favorable resolution.
We have had particular success in negotiating favorable settlements with the IRS, and, in our experience, a negotiated settlement almost always produces a better result for our clients. However, when it is not possible to negotiate a favorable settlement, we try cases. We have tried cases in all of the tax forums and have argued before appellate courts.
We have handled and resolved issues arising in a wide variety of contexts, including income tax accounting methods, bad debts, intangibles, insurance and financial products, executive compensation, research and investment tax credits, capitalization, valuation, transfer pricing, mergers and acquisitions, employment, and other excise taxes. We also have represented companies and individuals in connection with alleged tax shelter transactions and criminal tax enforcement proceedings.
Our litigators represent individuals and companies accused of tax and related criminal offenses in administrative and grand jury investigations, administrative conferences, and criminal trials.