Tax Controversy and Litigation

Our Tax Controversy and Litigation team counsels corporations, partnerships, and individuals in complex tax disputes ranging from civil tax controversies to criminal investigations and litigation. We regularly represent clients before the Internal Revenue Service, the Tax Division of the U.S. Department of Justice, U.S. Attorney’s Offices, and state and local tax authorities, and have handled some of the most significant tax investigations of the last decade.

Our team, which brings to bear extensive federal government experience, includes a former Deputy Attorney General and Principal Deputy Assistant Attorney General for Tax Matters; a former IRS Chief Counsel; and former federal prosecutors with extensive lead-counsel experience in the Tax Division and various U.S. Attorney’s Offices.

We handle matters that span the life cycle of both criminal and civil tax controversies.  In civil disputes, we counsel clients from examination through litigation and appeals.  In criminal matters, we represent clients in IRS administrative investigations, grand jury investigations, and if necessary, at trial.  We also have significant experience representing clients in tax-related Congressional investigations.  Our team has substantial courtroom experience -- we have tried cases in the U.S. Tax Court, the Court of Federal Claims, and various federal District Courts, and handled appellate matters through the federal Courts of Appeals and in the United States Supreme Court. We also have represented clients in high-profile congressional hearings.  In addition to litigating numerous substantive tax issues, we have significant experience with cross-border investigations, penalty actions, John Doe summonses, summons enforcement actions, and privilege and procedural issues that often arise in tax litigation.