Tax Controversy

Our experienced tax controversy team represents clients in disputes with the IRS, the U.S. Department of Justice (DOJ), and state and local taxing authorities.

Our diverse client base includes multi-national corporations, domestic corporations, closely held companies, partnerships, trustees, nonprofit entities, and individuals. Because our team has significant government experience, including with the DOJ Tax Division, the IRS, and state administrative agencies, we are familiar with the procedures, practices, and approaches of these authorities, and use this knowledge to the strategic advantage of our clients.

Our attorneys routinely handle tax audits, protest letters regarding tax or penalties, voluntary disclosures to taxing authorities, refund claims, requests for rulings, determination letters, technical advice, closing agreements, and disputes regarding income tax reporting, reporting forms, and potential penalties. We also assist clients in the tax collection process and find solutions that best suit their financial situation.

Although we focus on helping clients resolve matters quickly and efficiently to avoid litigation, including through the IRS Office of Appeals and “Fast Track” process, we also represent clients in civil and criminal tax controversy litigation before federal district and appeals courts, the U.S. Tax Court, the U.S. Court of Federal Claims, and state and local courts and administrative tribunals. Our attorneys combine civil and criminal litigation experience with technical knowledge of complex tax law issues and procedure.


Our client representation includes:

  • Successfully defended an international corporation in criminal tax investigation and civil audit relating to ten-figure inter-company transaction and nine-figure monetary liability. Result: no criminal charges and no civil fraud penalty.
  • Successfully defended a major insurance company in regulatory investigation relating to multi-billion dollar tax structures involving related businesses and offshore entities.
  • Successfully defended numerous individuals and businesses accused of multi-million dollar federal criminal and civil tax fraud schemes, including alleged schemes relating to business income tax evasion, personal income tax evasion, and payroll tax schemes.