Audits and Tax Controversies

Although a 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, particularly with the IRS.

When certainty is required in tax-related matters, we can work with our clients to prepare requests for private letter rulings from the IRS.  We also represent our clients in income, gift and estate tax audits.  These proceedings often involve complex property or business valuation issues which 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 U.S. Tax Court and have represented our clients’ interests in such litigation.