Find Lawyers in America for Litigation and Controversy - Tax
Practice Area Overview
Tax litigation and controversy broadly describes the practice of resolving tax disputes with federal, state, local, and foreign tax authorities. A tax controversy may involve a business (whether for-profit or not-for-profit), trust, estate, or individual, and can result from any form of taxation, including income tax, estate and gift tax, state sales and use tax, or local property tax. In general, tax disputes are separated into civil and criminal matters.
Civil Tax Controversies
Attorneys specializing in tax controversies may assist a taxpayer in a civil matter by providing expertise regarding substantive tax laws, dealing with revenue agents, formulating audit strategies, and pursuing administrative or judicial appeals. Although litigation is usually the option of last resort for most taxpayers, an experienced attorney can provide skillful representation in court proceedings. A tax attorney can play a leading role in resolving a tax controversy or simply serve as an advisor to the taxpayer or his or her accountant. In addition, an attorney may assist the taxpayer in planning transactions to avoid future disputes.
Civil tax matters usually begin with audit, assessment, and collection activities by a taxing authority. Alternatively, a controversy may be initiated by a taxpayer claiming a refund. At the federal level, resolving a civil tax controversy may require discussions with the IRS, a written appeal to and discussions with the Appeals Office, or, potentially, litigation in the United States Tax Court, District Courts, or Court of Federal Claims. After litigation of a case in a lower court, the taxpayer may have appeal rights in the federal appellate courts. A similar process is available in resolving civil tax controversies at the state and local levels.
An international tax attorney may assist a taxpayer in resolving issues with taxing authorities in foreign jurisdictions or involving issues arising in international transactions, including advanced ruling requests to achieve tax certainty and penalty protection, competent authority requests to resolve treaty issues, advanced pricing agreements to resolve transfer pricing issues, and using voluntary disclosure programs to prevent or reduce tax penalties.
Criminal Tax Controversies
Criminal tax matters involve taxpayers alleged to have evaded taxes or otherwise willfully violated the tax laws. Tax litigators can assist such taxpayers by representing them during criminal investigations by the IRS, the Justice Department, or state taxing authorities, and in criminal trials, sentencing proceedings, and appeals.
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George Abney offers his clients confident guidance through civil and criminal tax controversy matters. He honed his skills as a federal prosecutor for the Department of Justice, where he was recognized by former Attorney General John Ashcroft as a Tax Division Outstanding Attorney. George is a partner on the firm’s Tax Controversy Team, whose practice focuses on civil and criminal tax controversy matters. George has significant trial and appellate experience gained from years as a feder...
Bill Acker is a shareholder, director and corporate vice president. He maintains an “AV” peer review rating with Martindale-Hubbell Law Directory, the highest peer review rating for attorneys. He was also selected for inclusion in the 2010-2019 issues of Michigan Super Lawyers magazine featuring the top 5% of attorneys in Michigan in the practice area of Estate Planning & Probate. He has also been selected by his peers for inclusion in The Best Lawyers in America© 2020 in...
Jay Adams is a partner in the Tax Practice Group and leader of the state and local tax team. Through partnering with his clients, Jay has developed a broad knowledge of the energy, manufacturing, healthcare, transportation, and retail industries that allows him to provide comprehensive and cost-effective advice in those areas. For more than 25 years, Jay has represented clients in matters involving virtually every type of state and local tax and in numerous jurisdictions. He has successfully ...
William F. J. Ardinger is a shareholder and the Treasurer of Rath, Young and Pignatelli, P.C. He serves on the Firm’s Executive Committee and heads the Firm’s Tax Practice Group. Bill focuses his practice on U.S. federal and state tax matters, business transactions, financial and wealth planning, and public policy issues. He assists clients in structuring business transactions in a tax-efficient manner and planning multi-jurisdictional business structures and systems. Bill represe...
Anson H. Asbury is the founder and managing shareholder of the Asbury Law Firm. Anson represents clients in federal and state tax controversies, complex tax litigation, criminal tax investigations and criminal tax litigation. Anson is a Fellow of the American College of Tax Counsel and the American Bar Foundation. He is recognized by Chambers USA for his expertise in Tax Litigation. He is rated among the Best Lawyers in America for tax law and has been selected annually as a Georgia Super Law...
Mr. August is a shareholder in the firm. Mr. August has been with the firm since 1994. He is a certified specialist in the fields of both Taxation Law, and Estate Planning and Probate by The Supreme Court of South Carolina. He is listed in the book The Best Lawyers in America in the fields of Bursiness Organizations, Closely Held Companies and Family Businesses Law, Litigation and Controversy - Tax, Tax Law, and Trusts and Estates Law. He received his Bachelor of Arts Degree, magna cum laude ...
Bill Backstrom is a partner and leader of the firm’s Tax Practice Group. For more than 35 years, he has focused on state and local tax matters in Louisiana and on a multistate basis. Bill provides comprehensive, practical, and solution-focused tax guidance to a broad range of business enterprises. Known for the quality of his counsel, his commitment to client service, and his ability to explain sophisticated issues in clear terms — particularly with respect to Louisiana’s hi...
John Keeling Baker has extensive experience in successfully trying and appealing a variety of business tort, contract, real estate, taxation, and class action suits before state and federal trial courts, Arkansas appellate courts, and the Eighth Circuit Court of Appeals in St. Louis, Missouri. He frequently works on behalf of clients on both sides of the Arkansas Freedom of Information Act (FOIA). He routinely advises governmental clients on open meetings and public records compliance require...
Gregg Barton, a partner in the firm’s Business practice, has 25 years of experience focusing on state and local taxes principally in Washington (including Seattle, Bellevue and Tacoma matters), Oregon and Alaska. His experience includes advising clients with respect to gross receipt, sales and use, net income, ad valorem , real estate excise and public utility taxes, seeking private rulings, handling administrative appeals and litigating in state courts.
Vincent J. Beres is a shareholder in the firm's Business Law, Tax and Tax-Exempt Organizations Practices. While Vince's clientele consists of businesses, ranging from partnerships and LLCs, S corporations, closely held businesses and large national manufacturing and service corporations, he also has deep experience as a trusted business and family advisor to individual business owners. Representative Matters and Experience Helping a food manufacturing client in the acquisition, development an...
Kathryn is a shareholder of the firm and a member of the firm’s Tax Practice Group, where she concentrates her practice in assisting clients with state and local tax matters. Kathryn’s practice focuses on matters before the New Hampshire Department of Revenue Administration, the Massachusetts Department of Revenue, and the Vermont Department of Taxes. Prior to joining the firm in 2007, she was with the state and local tax practice of PricewaterhouseCoopers, LLP in its Chicago offi...
Jon Block represents and advises clients with Maine, New Hampshire, and Massachusetts tax problems. Jon litigates tax cases at the administrative level and through all levels of the court system, advises clients on transactional and multistate tax issues, obtains advance rulings for clients, and does a substantial amount of legislative and government relations work in the tax area. Jon's substantive expertise in state and local tax encompasses corporate and individual income tax, business pro...
Megan L. Brackney has a distinguished track record of delivering exceptional results for clients facing complicated and difficult tax issues. An expert in the interplay between civil and criminal tax controversies, Ms. Brackney develops innovative strategies to resolve compliance concerns, civil audits, and criminal investigations. Ms. Brackney also advises clients on tax issues that arise in other contexts, such as business and matrimonial disputes, and she represents clients in litigation i...
John Brusniak, Jr. has been a nationally recognized property tax attorney for 40 years. Before starting his own firm, John was a partner in two of Texas’ largest law firms. As a result of his ground-breaking appellate and other successes, Texas property tax law bears his personal mark. He is a frequently sought speaker and publisher of property tax articles, as well as his own reference book, Brusniak’s Texas Property Tax Digest. John is also the author of Texas Property Tax Code ...
Bill's law practice focuses on a wide variety of tax, corporate and business matters, including deferred compensation, equity based incentive plans and the purchase and sale of owner-managed businesses - with an emphasis on developing exit strategies for the family or closely-held business owner. He also counsels clients on various federal, state and local tax issues. Thriving on creative solutions to complex issues, and believing that “if you are through changing, you are through&rdquo...
Andre Burvant is a partner in the Tax Practice Group. Andre counsels clients on state and local tax planning, audit defense, tax refunds and credits, and represents businesses and individuals in tax controversy work before the Louisiana Department of Revenue and local parish taxing agencies. Andre also represents clients in tax controversies before the Louisiana Board of Tax Appeals and in state and federal courts. Andre is a contributor for Cooking with SALT, a legal blog committed to provid...
Clark Calhoun represents clients in state tax controversy and litigation matters in Georgia, California, and other states before state taxing authorities, city and county boards, state trial and appellate courts, and the U.S. Supreme Court. He has secured a multimillion-dollar income tax refund in a Georgia Tax Tribunal action, received a refund of overpaid 911 taxes, defended companies against unjustified state transfer-pricing assessments, and earned property tax refunds for nonprofit entit...
Mr. Carpenter's primary practice areas include tax, estate planning and probate law, IRS tax controversy, asset protection planning, business mergers and acquisitions, and commercial real estate law. He is a NC Board Certified Specialist in Estate Planning and Probate Law. Mr. Carpenter specializes in estate planning, estate administration, representing clients before the IRS, asset protection planning, and sophisticated real-estate tax-deferral strategies, including capital gain maximization...
Caroline D. Ciraolo, former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, is a partner with Kostelanetz LLP and a founder of its Washington, D.C. office. Her practice focuses on federal and state civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing related tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and pro...
With his deep knowledge and breadth of experience in law and taxation, Mr. William R. Culp, Jr. helps clients structure their business affairs to maximize their wealth. Mr. Culp represents a wide variety of clients, from entrepreneurs and private investors to large corporate clients. Clients look to him for guidance in structuring complex business arrangements and transactions, and for solutions to the most challenging business problems. Mr. Culp's practice includes real estate and partnershi...
Jack Cummings is counsel in the Federal Tax Group of Alston & Bird in Raleigh and Washington, D.C. He served as IRS associate chief counsel (corporate) and chair of the Corporate Tax Committee of the ABA Section of Taxation. His books include The American Jobs Creation Act of 2004 (with Robert Hanson), The Supreme Court’s Federal Tax Jurisprudence published by the American Bar Association in 2010 and The Supreme Court, Federal Taxation and the Constitution , published by the America...
Robert Dallman’s practice includes advising clients in complex federal and state tax audits, administrative appeals and tax litigation; tax planning; and business planning. Formerly an IRS?trial attorney in Washington, D.C. and Milwaukee, he has practiced either for or against the IRS and selected state taxing authorities for more than 20 years.
C. Fred Daniels is a partner in the firm’s Birmingham, Alabama office, where his practice emphasizes estate and gift planning, administration of estates, taxation, closely-held businesses, and litigation involving the rights and duties of personal representatives and beneficiaries. Mr. Daniels has been the lead trial and appellate counsel in numerous estate, gift and income tax cases including O’Neal v. United States, 258 F.3d 1265 (11th Cir. 2001) (establishing that, in the Eleve...
Tom Daniel concentrates his law practice in federal and State tax planning, resolution of tax disputes, organization and structuring of business ventures, solving practical business legal problems, purchases and sales of businesses, structuring and acquiring real property interests, and structuring tax-advantaged means for acquiring, holding, operating and disposing of real estate and business investments. Mr. Daniel also provides estate and trust planning advice and services for his clients....
David A. DeJarnett is a partner in the Martinsburg office of Bowles Rice and concentrates his practice in trust and estate law, federal and state taxation, and corporate, LLC and partnership law. His estate planning practice includes providing clients with planning techniques to meet their objectives. These objectives may include minimizing the effect of estate, gift and generation-skipping transfer taxes through the use of credit shelter trusts, charitable remainder trusts and irrevocable li...
Chair of Stein Sperling’s nationally regarded tax law group, David De Jong is a recognized and highly sought industry authority with more than 40 years of experience. Raised in Montgomery County, David always intended to practice law in his “home town”. He has been instrumental in maintaining Stein Sperling’s collegial, small-firm feel while helping its tax department grow into a regional powerhouse. David has a gift for putting himself in his clients’ shoes to g...
After serving as a law clerk for a Federal judge in Los Angeles, Mike began his career in tax controversy as a Trial Attorney with the Attorney General’s Honors Program at the Tax Division of the U.S. Department of Justice. After the Justice Department, Mike worked at a boutique tax firm in Washington, D.C., where he was elected partner in 2004. In this capacity he represented clients ranging from Fortune 100 companies to partnerships and individuals. Mike returned to government in 2005...
Jeff chairs Varnum's employee benefits practice group. He has 25 years of experience working with employers, executives and third-party administrators on a wide range of employee benefit, executive compensation and individual retirement matters, including plan design, plan administration, benefit plan disputes and tax planning for retirement. He also helps solve complex tax issues in business and investment transactions, especially those involving pass-through entities and oil and gas activit...
Cody leads Dickinson Law’s state and local tax practice and focuses on sales, use, and property tax controversy and litigation, multistate taxation , and general sales and use tax counseling. Cody has successfully represented before Departments of Revenue taxpayers of all sizes in industries including construction, manufacturing, health care, hospitality, technology, and agriculture. Mr. Edwards takes a creative approach to the practice of law, which includes utilizing the tools provide...
Curtis Elliott has practiced tax law for more than 25 years. He helps entrepreneurs and family business owners address their tax, estate planning, trusts and estates and business succession planning goals. Mr. Elliott has deep experience helping business owners develop estate planning structures for their family businesses. His clients range from closely held companies to large industrial enterprises owned and actively managed by multiple family generations. His work involves the use of share...
Bruce Ely’s more than 40 years of experience have allowed him to handle projects as diverse as serving on the recruiting teams that successfully induced both Mercedes-Benz and Hyundai to locate their first U.S. manufacturing plants in Alabama to representing taxpayers before the Internal Revenue Service, the Alabama Department of Revenue and local taxing authorities. His practice focuses on three concentric areas: representing taxpayers in federal, state and local administrative and jud...
G. Michelle Ferreira counsels individuals, partnerships, estates and corporations in tax disputes with the Internal Revenue Service and state and local tax agencies, including the California Franchise Tax Board, the State Board of Equalization, the Employment Development Department and county assessment appeals boards. As a former tax litigator for the Internal Revenue Service, Michelle brings unique experience to clients who have complex and sensitive tax and penalty disputes. Michelle repre...
RANDY E. FISHER is an attorney with the law firm of Thomas & Fisher, P.A. in Greenville, South Carolina. He practices in the areas of taxation, estate planning, trusts and estates, probate, partnership, limited liability company and corporate law, and mergers and acquisitions. He is a certified specialist in the fields of both Taxation Law, and Estate Planning and Probate Law by The Supreme Court of South Carolina. He is listed in The Best Lawyers in America in the fields of Taxation Law,...
Kevin M. Flynn is a forceful advocate with proven skills in litigating federal civil and criminal tax controversies for clients with complex tax challenges. Mr. Flynn’s particular experience in civil tax issues has led to him trying and winning numerous tax cases involving a broad range of corporate, partnership, personal income tax, and employment tax issues. Mr. Flynn’s strong negotiating skills and business judgment have allowed him to achieve extraordinary results for clients ...
Mr. Fox is the managing partner of Ivins, Phillips & Barker. He was named in 2012 by the Washingtonian Magazine for the fourth straight year as one of the outstanding tax lawyers in Washington, D.C., in the Washington Post Magazine's list of Super Lawyers for the third straight year, and has been named in Best Lawyers in America in each of the last ten consecutive years. Although, during his 47 years with the firm, Mr. Fox devoted a substantial portion of his activities to international a...
Mr. Freeman is the founding and managing member of Freeman Law, PLLC. He is a dual-credentialed attorney-CPA, author, law professor, and trial attorney. Mr. Freeman has been recognized multiple times by D Magazine as one of the Best Lawyers in Dallas, and by Super Lawyers and Texas Monthly magazine. He was recently honored by the American Bar Association, receiving it’s “On the Rise – Top 40 Young Lawyers” in America award, and recognized as a Top 100 Up-And-Coming Att...
Elliot Freier is a Partner and concentrates his practice on the taxation of mergers and acquisitions, establishing and growing companies, bankruptcy and workout taxation and tax controversy representation. Recognized as a leading tax lawyer by Chambers USA, Elliot counsels clients on the taxation of transactions in multiple sectors, including high tech, medical devices, retail, media and entertainment, among others. He has substantial experience advising private equity and other business clie...
Abbey Garber focuses his practice on tax litigation and providing advice in connection with applying tax laws to individuals, estates, corporations, and partnerships. Serving more than 30 years in the Office of Chief Counsel at the Internal Revenue Service, he tried cases of all sizes in Tax Court, earning significant favorable opinions in fraud, tax shelter, and many other cases; received a full Tax Court opinion in an attorneys’ fees case; and prosecuted criminal tax cases in United S...
Joe’s practice is focused on federal, state and local taxation, including planning and controversy resolution. Joe has represented clients successfully before the Tennessee tax administrative bodies and before Tennessee courts, including the Tennessee Supreme Court. Joe represents a number of Fortune 500 companies with respect to their Tennessee tax matters. Joe also represents clients in federal tax controversy resolution, including administrative appeals and representation before the ...
LANCE A. GILDNER is an equity partner in the Dayton office of Taft Stettinius & Hollister LLP. He received his undergraduate degree from Indiana University and law degree from the University of Dayton School of Law. He specializes in tax law with a primary focus on tax controversy. With almost 22 years in practice as a tax attorney and an Ohio State Bar Association (OSBA) certification as a Federal Tax Specialist, Mr. Gildner has developed a breadth of knowledge and experience dealing wit...
Fred Goldberg is co-head of the firm’s Tax Group and global co-chair of the firm’s Diversity Committee. Mr. Goldberg first joined Skadden in 1986, following two years as chief counsel of the Internal Revenue Service. From 1989 until 1992, Mr. Goldberg served as commissioner of the IRS, and during 1992 he served as assistant secretary of the Treasury for Tax Policy. He returned to Skadden in December 1992. Working with his Tax Department colleagues in Skadden’s Washington, Ne...
Armando Gomez concentrates his practice on a broad range of tax matters. He advises clients on the structuring and financing of U.S. and international partnerships, joint ventures and other cross-border transactions. Mr. Gomez also represents clients in connection with structuring private equity investments and investments in renewable energy projects. In addition, he counsels on valuation and transfer pricing matters, at both the planning and controversy stages. Mr. Gomez represents clients ...
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