Administrative Tax Appeals
Our primary goal in the resolution of any tax dispute is to win the case. We define a “win” as the resolution of tax issues at a very substantial discount from the amount originally sought by the taxing authority or in a manner that our client can afford without negatively impacting the client’s ongoing financial/business health. We are known for developing thoughtful and innovative solutions to seemingly impossible situations. On a number of occasions, we have settled appeal matters without any additional tax liability to our client and some we have settled with a refund due the client. We seek to win each client’s tax dispute by persuasive negotiation without the need for litigation, but when litigation is required, we are prepared to go the distance and our counterparts at the IRS and state taxing authorities know this. Our government counterparts respect us (and some even enjoy working with us) knowing that we will creatively resolve the tax issue for our client’s benefit and provide the tax agent with sufficient documentation to close out the matter without management dispute.
We have collective experience in virtually every facet of tax law and, because tax disputes are rarely just about tax law, we have also developed a keen understanding of related areas of law, including corporate, limited liability company, intellectual property and technology, labor and employment, and employee benefits.
Through the appeals process we have successfully resolved matters involving the characterization of income; the deductibility of expenses of every type and nature; arcane estate tax issues; the timing of the recognition of income and/or expense; as well as a host of other issues too extensive to list.