Gould + Ratner

Tax Controversy

Our lawyers’ paramount goal in representing clients in tax, financial and business matters is to, whenever possible, avoid controversies with taxing authorities. Yet, when a legitimate dispute arises, we are uniquely prepared to pursue our clients’ rights zealously and in any forum in which those disputes may be resolved. 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 U.S. District Court, U.S. Circuit Court of Appeals and U.S. Tax Court.

Tax disputes require experienced tax and trial lawyers. Our team possesses the business acumen and trial skills necessary 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 are involved in a wide-range of business sectors, and include individuals and private trusts, partnerships, limited liability companies and corporations. Disputes range from simple, evidentiary matters to complex and technical tax matters. We tailor our solutions to fit each client and each case, never losing sight of the financial and business implications.


Representative Matters

  • Advisor to individuals and businesses seeking to resolve federal and state tax liabilities, including tax amnesty programs, offer in compromise, installment agreements and release and subordination of tax liens.
  • Advisor to individuals and businesses in tax controversy matters involving: franchise, income, estate and gift, replacement, sales, and use taxes.
  • Handled tax refund claim for client for claim of right involving the partial repayment of purchase price on sale of business.
  • Handled tax refund claim for client on cancellation of debt income for S corporation that allowed a client to claim additional tax losses.
  • Handled numerous offers in compromises for clients to settle tax deficiencies ranging from 10 cents on the dollar up to 40 cents on the dollar.
  • Representation of former top executive of billion-dollar commercial real-estate investment management firm prosecuting treatment of income against Internal Revenue Service.
  • Representation of legal and tax professionals prosecuting and defending against claims involving development and sale of tax preparation services and strategies. 
  • Handled examination and appeals cases for a multimillion-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 Internal Revenue Service.
  • Litigated appropriate computations of depletion deductions for client’s mineral deposits.
  • Successfully contested Internal Revenue Service denial of qualified research expense deductions.
  • Litigated deductibility of various business expenses.
  • Successfully defended against Internal Revenue Service allegations of inadequate corporate capitalization and disguised dividends.
  • Resolved contested valuation matters in estate and gift tax reviews.
  • Represented numerous estates in audits of federal estate tax returns.
The touchstone of our service to clients is translating our legal skill and business experience into practical solutions that work, helping our clients succeed.