Our Tax Controversy and Litigation Group represents clients in high-stakes, complex tax controversies. We work with clients to resolve a wide range of tax disputes with federal, state and local taxing authorities. We actively participate with our clients and their accountants in quickly resolving tax controversies at the audit and appellate level before the Internal Revenue Service (IRS), the California Franchise Tax Board (FTB), the California Department of Tax and Fee Administration (CDTFA), the California Employment Development Department (EDD), in addition to county and local taxing authorities.
With our broad experience and perspective on how federal and state tax authorities apply tax laws to individuals and businesses of all sizes, we advise our clients on their options, to develop their positions, negotiate settlements, and efficiently resolve disputes.
We represent clients in all phases of tax controversy; from the beginning of a tax audit, to the preparation of tax protests and negotiation with IRS Appeals, to litigation in the United States Tax Court, the Federal District Courts, and the Court of Federal Claims. Similarly, at the state level, we represent taxpayers in all phases of the controversy and litigation process with an emphasis in California taxation.
In criminal tax matters, we represent companies and individuals who are alleged to owe tax or be liable criminally for failure to comply with the tax laws. Representative engagements include defending taxpayers against allegations of failure to report income, fraudulent overstatement of deductions, preparation of false tax returns, failure to collect and pay over employment taxes, and conspiracy to obstruct the collection of taxes.
We aim to achieve unsurpassed results at all levels of a tax dispute, from the audit examination to collection and litigation. We assist in the following matters: