Our attorneys have represented corporate, individual, and institutional taxpayers in tax controversies involving examinations and appeals of federal income tax, excise tax, estate and gift tax, and state and local income, excise, sales and use, and property tax issues. We have experience in dealing with the Internal Revenue Service and state and local governments at all levels of administrative proceedings, regularly handling audits at the initial stage and through the appeals process. In addition, we have worked extensively on issues dealing particularly with the Alcohol and Tobacco Tax and Trade Bureau.
We assist our clients in seeking proactive resolution of all types of tax controversies, including:
- seeking private letter rulings
- negotiating settlements of disputed tax positions
- participation in voluntary disclosure programs
- offers in compromise; and
- collection due process hearings.
When necessary, however, we are prepared to protect our clients' positions through litigation in federal and state courts, including the United States Tax Court.