Tax controversies

Our corporate tax team acts for clients in disputes and litigation over federal, state and local tax matters. We represent clients in matters concerning income, estate and gift taxes, and sales and use taxes.

We have particular experience in representing clients in estate, gift and income tax audits, and we negotiate with both the federal and the state tax authorities. Where possible we seek to resolve issues out of court.

Recent work

  • Litigating refund claim before New York State Division of Tax Appeals on income sourcing issues.
  • Representing entrepreneurs before United States Tax Court on petition challenging denial by Internal Revenue Service of trade or business expenses.
  • Obtaining an important appellate victory before the Federal Circuit Court of Appeals, involving corporate reorganization, tax loss utilization and consolidated return issues.
  • Representing non-residents in audits by New York.

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