U.S. Tax Court

The Office represents individuals and businesses before the United States Tax Court. The Office handles all aspects of Tax Court practice including the filing of a petition, case preparation, discovery, depositions, stipulations, settlement conferences, hearings, post-trial briefing, and appeal. Tax Court actions include:

  • Tax litigation to determine whether proposed deficiencies in income, estate and gift taxes are correct
  • Claims for relief from joint and several liability (innocent spouse cases)
  • Review of final partnership administrative adjustments
  • Collection due process cases
  • Determination of worker classification (employee versus independent contractor)
  • Tax shelters and promoters

Tax Litigation in U.S. District Court

  • Suits challenging the validity of tax determinations by paying the disputed tax and commencing a suit for refund
  • Defense to enforcement of an IRS summonses
  • Defense to foreclosing tax liens by sale of property
  • Defense to suit reducing tax assessments against a taxpayer to judgment
  • Defense to obtaining judgments against third parties, including estate fiduciaries for liability, transferees of property from insolvent estates to the extent that they received property subject to federal tax liens, and transferees of fraudulently conveyed property, who may be liable under state law
  • Wrongful levy actions
  • Defense to collecting estate tax from property of decedent

California State Court Litigation

The Office represents individuals and businesses in tax litigation with the California Franchise Tax Board, State Board of Equalization, Employment Development Department and other tax agencies.