Federal Tax Controversy + Litigation


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Our work includes tax audit, dispute resolution proceedings, and litigation regarding all types of federal taxes before the IRS, the Tax Court, the Court of Federal Claims, 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 administratively, and after filing suit in the Tax Court or refund court. In our experience, a negotiated settlement almost always produces a better result for our clients. 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 transfer pricing, income tax accounting methods, insurance and financial products, bad debts, intangibles, employment, executive compensation, research and investment tax credits, capitalization, valuation, mergers and acquisitions, and various excise taxes. We also have represented companies and individuals in connection with summons enforcement proceedings, alleged tax shelter transactions, and criminal tax enforcement proceedings. We represent individuals and companies accused of tax and related criminal offenses in administrative and grand jury investigations, administrative conferences, and criminal trials.

U.S. News Best Lawyers® Law Firm of the Year 2016
Litigation – Tax


U.S. News Best Lawyers® Best Law Firms 2017
National: Litigation – Tax (Tier 1)
National: Tax Law (Tier 1)
New York: Litigation – Tax (Tier 1)
New York: Tax Law (Tier 1)
Sacramento: Litigation – Tax (Tier 1)
San Francisco: Litigation – Tax (Tier 1)
San Francisco: Tax Law (Tier 1)
Washington, D.C: Litigation – Tax (Tier 2)
Washington, D.C: Tax Law – (Tier 1)


Chambers USA 2017
National: Tax Controversy
California: Tax
New York: Tax


Law360
2013 Tax Practice Group of the Year


Legal 500 US 2017
International: Tax
US Taxes: Financial Products
US Taxes: Contentious
US Taxes: Non-Contentious


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U.S. News – Best Lawyers® Law Firm of the Year 2016
Litigation – Tax

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