Tax Audits and Appeals
A substantial part of our practice involves representing major US companies in preparing for and defending against Internal Revenue Service proposed tax adjustments on audit.
- Group lawyers prepare protests and are involved in negotiations with the Appeals Office of the Internal Revenue Service.
- In addition, the group has pursued administrative tax appeals in many states across the country involving income, sales, and excise taxes.
Representative engagements include:
- Represented client in a bench trial before the US Court of Federal Claims arising out of tax issues associated with participation in international partnership. Decision in favor of client.
- Represent clients before the US District Court and US Tax Court in connection with issues relating to research and experimental deductions and credits.
- Represented clients in bench trials before the US District Courts in an administrative summons enforcement action and a proceeding to quash a formal document request (section 982) relating to the admissibility of documentation maintained in foreign countries. The District Courts found in favor of client.
- Represented client before the US Tax Court in connection with deduction for expenses to resist takeover attempt. A favorable settlement resulted in connection with this litigation.
- Represented client before the US Tax Court in connection with section 382 and separate return limitation year issues. The government conceded the case on the eve of trial.
- Represented client before the US Court of Federal Claims in connection with the constitutionality of the harbor maintenance tax. The Supreme Court in a related case resolved the issue in favor of the company.
- Represented client in connection with a bench trial before the US District Court in connection with argument that assessment was invalid because statute extension had not been validly executed. Decision in favor of the client.