Introduction
Key Contacts
Focus Areas
Examinations
We represent clients in all types of civil tax examinations, including income tax examinations of corporations and individuals, partnership examinations, employment tax examinations, promoter and preparer penalty examinations, and preparer penalty examinations.
We have experience with a broad range of issues ranging from the proper reporting of income and deductions to foreign information reporting and associated penalties, prohibited transactions, and withholding obligations related to payments to foreign recipients. We are especially sensitive to “eggshell audits,” where civil examinations run the risk of evolving into criminal investigations. In addition, we represent tax professionals before the IRS Office of Professional Responsibility. Our goal is to resolve the underlying dispute without having to resort to litigation.
Civil tax litigation
Civil litigation can be costly. We work with our clients to define case-specific objectives that allow the matter to be handled within the client’s financial constraints.
We know substantive and procedural tax laws, so we evaluate the strengths and weaknesses of each case to advise the client on risks and devise a strategy to obtain a favorable settlement or, if necessary, persuasively advance their position at trial.
Criminal tax violations
Described as “a haven for clients in trouble,” by The American Lawyer, we often apply our white collar defense experience to clients with criminal tax issues. Our detailed understanding of the investigative tools that the IRS employs and the procedures that the IRS must follow to refer a case to the DOJ for prosecution enables us to effectively advocate for our clients in order to avoid prosecution.
When necessary, our team of former government regulators, enforcers, prosecutors, and defenders supports our tax practice to litigate at trial and counter the government’s case. We have tried criminal tax cases to verdict and, when clients decide trial is not in their best interests, negotiated plea agreements for favorable sentences. Our team has also handled criminal tax appeals in federal and state courts of appeal.
