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Tax Controversy

“The Power to tax is not the power to destroy while this Court sits…” – Justice Oliver Wendell Holmes

When facing complex controversies with Federal and state tax authorities, taxpayers from wealthy individuals to Fortune 500 companies have relied upon our firm’s unparalleled depth of experience and knowledge in resolving these sensitive matters. We were founded by two tax litigators, and helping taxpayers through tax audits, appeals, and litigation has remained one of the Firm’s most important strengths.

Our tax controversy lawyers have the decades of experience and background it takes to successfully resolve your matter.

  • When national news publications need insight into tax controversy issues, our lawyers are the ones they call—and quote.
  • We have handled, from audit through litigation, some of the most complex and high profile tax disputes in the country—for clients from Alaska to Florida.
  • We have served with the United States Tax Court (as attorney-advisor), with the United States Department of Justice, and with the California Court of Appeal.
  • We have authored numerous articles and treatises on tax law and tax procedure.
  • We are frequently asked to sit on and moderate panel discussions on tax controversies around the country.

If it’s tax-related, and it’s disputed, we know how to help. Our attorneys represent taxpayers in the resolution of Federal and state civil tax audits, appeals, and litigation, Federal and state criminal tax investigations, Grand Jury investigations, and criminal trials. We also handle disputes in connection with estate and gift tax audits, appeals, and litigation, ERISA and DOL penalties and judicial forfeiture proceedings.

Our tax trial attorneys are licensed to practice before the Internal Revenue Service, California Franchise Tax Board, California State Board of Equalization, California Employment Development Department, County Assessors and Assessment Appeals Boards, US Tax Court, US Court of Federal Claims, all Federal District Courts in California, the Eastern District of Michigan, the 9th Circuit Court of Appeals, the US Supreme Court, and California state courts.

If you have a tax controversy matter, we can help. We have the experience, credibility, and tenacity to successfully resolve the most sensitive tax controversy matters. We have done that for many years for our clients—and we’d be glad to do it for you, as well.