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| Tax Controversies |
Taxpayers facing an IRS audit or questions about state tax liability need experienced counsel to advocate on their behalf in tax return examinations and, when necessary, to litigate vigorously.
Our team of tax controversy lawyers includes former litigators from the Chief Counsel's Office and the District Counsel, IRS; a former U.S. Tax Court Attorney-Advisor; a former Attorney-Advisor to the Assistant Secretary of Tax Policy in the Office of Tax Legislative Counsel, Department of Treasury; and a former U.S. Department of Justice Trial Attorney.
Representative Matters:
- Represented clients during the audit process before the IRS and state taxing authorities and requested rulings as needed
- Pursued administrative appeals of tax examiners' decisions
- Negotiated and structured settlements of tax liabilities and closing agreements with the IRS and state and foreign tax authorities
- Litigated administrative determinations of tax controversies in federal, state and local courts
- Defended taxpayers from tax liens and collection activities by the IRS and state taxing authorities
- Structured "offers in compromise," installment agreements and other settlements of tax liabilities
- Served as expert consultants and witnesses in tax and other controversies
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