Tax Controversy
Tax disputes require experienced tax and trial lawyers. Our Tax Controversy Group is comprised of lawyers who understand taxation and have the trial skills to win cases. We provide sound transactional and controversy advice in federal taxation matters as well as in state and local tax disputes.
Our clients represent a broad cross-section of the business community and include individuals and private trusts to partnerships, limited liability companies and corporations. Their disputes range from simple evidentiary matters to complex and technical tax matters. Each is unique. We tailor our representation to fit each client and each case, never losing sight of the overall financial and business issues impacted by the controversy.
Gould & Ratner's paramount goal in representing clients in tax, financial, and business matters is to, wherever possible, avoid controversies with taxing authorities. Yet when a legitimate dispute arises, we assess our client’s rights and the remedies available to resolve it. We regularly represent clients in audits, collection actions, offers in compromise, installment agreements, and other negotiated settlements with taxing authorities. We represent clients in the United States District Court, the United States Court of Appeals, and the United States Tax Court.
The professionals in our Tax Controversy Group are comprised of lawyers from our Tax and Financial and Litigation Groups. These lawyers bring decades of insight and experience to each controversy.
Representative Engagements:
- Handled examination and appeals cases for a multi-million dollar refund claim.
- Litigated proper tax treatment of executive’s structured compensation payments.
- Litigated inadequacy of deductions taken by S corporation on behalf of shareholder.
- Established favorable tax cost basis in property in contest with IRS.
- Litigated appropriate computations of depletion deductions for client’s mineral deposits.
- Successfully contested IRS denial of qualified research expense deductions.
- Litigated deductibility of various business expenses.
- Successfully defended against IRS allegations of inadequate corporate capitalization and disguised dividends.
- Resolved contested valuation matters in estate and gift tax reviews.