Tax Litigation

Our tax litigation experience encompasses virtually every type of case before the United States Tax Court including companies, investors, individuals, partners, trusts, and estates. Our lawyers resolve cases through negotiated settlement with the IRS Office of Appeals, by trial and, if necessary, by appeal. We aggressively seek to minimize our clients tax liabilities without compromising ethical principles. We have earned a reputation among clients for understanding the complex rules of tax practice and procedure and solving our clients’ problems in unique and innovative ways. The firm is known and well respected by government tax officials, which benefits our clients in resolving complex tax controversies.

Our U.S. Tax Court practice includes:

    • Deficiencies determined by the Commissioner with respect to income, estate, or gift tax cases
    • Claims for relief from joint and several liabilities (innocent spouse cases)
    • Worker classification cases (i.e., independent contractor or employee)
    • Collection Due Process cases

    Tax litigation in federal district court includes:

    • Refund litigation
    • Challenges to the enforcement of IRS summonses
    • Suits related to wrongful levy
    • Review of IRS collection actions before levy on principal residence
    • Suits to reduce tax assessments to judgment
    • Interpleader, quiet title, foreclosure, or other actions involving property in which the IRS may claim an interest