Tax
Litigation with the IRS
Although the primary focus of our practice has always been planning and counseling,
we also represent our clients in both administrative and court proceedings involving
tax disputes.
When certainty is required in tax-related matters, we can work with our clients
to prepare requests for private letter rulings from the Internal Revenue Service.
We also actively represent our clients in income, gift and estate tax audits.
These proceedings often involve complex valuation issues that arise in the assessment
of gift, estate and generation-skipping taxes.
While it is our objective
that disputes with the IRS be resolved at the administrative level, some tax disputes
ultimately must be resolved through court proceedings. In such situations, our
attorneys are admitted to practice in the United States Tax Court and can represent
our clients' interests in such litigation.