Practice Subgroup

Tax litigation

When attempts to settle with the IRS fail, we fight the IRS in either U.S. Tax Court or as a refund case in federal district court. Our tax attorneys have extensive experience in trying Tax Court cases, causing the IRS to rethink their position, resulting in many cases settling prior to trial.

However, some of our cases are fully litigated. We average about two-to-three reported Tax Court decisions each year. Recent cases litigated have dealt with such issues as estate tax, son-of-boss transactions, abatement of penalties, review of collection due process hearings, reasonable compensation, innocent spouse relief, amortization of covenants not to compete, bona fide loan, charitable deduction related to facade easements, and deductibility of medical expenses.