Litigation in U.S. Tax Court, the U.S. Court of Federal Claims, and U.S. District Courts seeking redeterminations of asserted deficiencies, payments of tax refunds to taxpayers, and recovery by the government of erroneous refunds. Issues in those cases have included a variety of deductions and credits; characterization of business transactions; changes in accounting methods; passive activity and at-risk limitations; treatment of damages and settlement payments; treatment of payment obligations as debt; treatment of dispositions of property used in trade or business; captive insurance; fuel excise taxes; estate taxes; U.S. Virgin Islands residency; and subpart F inclusions

Litigation in U.S. District Courts related to tax procedure and administration. Issues in those cases have included enforcement of IRS summonses; failure to report foreign bank accounts; damages for unauthorized collection actions; claims for injunctive and equitable relief against the IRS; return preparer injunctions; and IRS collections, including the validity and priority of federal tax liens, third-party liability, and fraudulent and voidable transfers

Litigation in U.S. Bankruptcy Courts related to objections to IRS claims; disgorgement of plan payments to IRS; violations of the automatic stay; and annulment of the automatic stay

Litigation in state courts concerning allegations of fraud and lack of economic substance; penalties for promoting abusive tax shelters; collection of federal taxes from probate distributions; and collection of federal taxes from distributive interests in LLCs

Representation in IRS examinations related to issues including changes in accounting methods; treatment of settlement payments; executive compensation; alternative energy incentives; disguised sales; gift taxes; subpart F inclusions; transfer pricing; and foreign tax credits

Obtaining relief from IRS and state taxing authorities for issues such as late filings; employment tax compliance; information reporting; and penalty abatements; as well as representing taxpayers making sensitive voluntary disclosures to the IRS and state taxing authorities

Advising individuals, businesses, trusts and estates, and non-profit organizations about the tax treatment (including reporting and withholding requirements) of specific types of payments or financial transactions, such as settlements, bonuses, non-cash charitable contributions, non-employee compensation, gambling winnings, and purchase price adjustments

Advising individuals, businesses, trusts and estates, and non-profit organizations about federal and state tax consequences of entity formation, financing, reorganization, merger and acquisition, and liquidation transactions; revisions to governing documents; and ongoing operations