Client Services / Tax / Tax Controversy

Tax Controversy

McDermott Will & Emery lawyers represent clients on all aspects of federal tax controversy matters, including Internal Revenue Service audits and appeals, competent authority matters and trial and appellate litigation.  We also are experienced with the numerous alternative dispute resolution options available to taxpayers during the audit and appeals process.  The 2008 edition of Chambers USA: Leading Lawyers for Business nationally ranked McDermott’s Tax Controversy practice.  The 2007 edition of The Legal 500 –United States recognized McDermott as a leading firm in the tax controversy area.

Our tax controversy lawyers regularly represent some of the world’s largest corporations on complex U.S. and international tax issues, often with hundreds of millions of dollars in controversy.  Most of these tax controversy matters are successfully resolved without litigation.  But when administrative settlement is not possible, we have extensive experience representing our clients in tax litigation at the trial and appellate levels, including before the U.S. Supreme Court.

In addition to handling a wide range of substantive tax issues, we also are experienced in handling procedural and litigation issues, including discovery disputes and attorney-client privilege issues.  Furthermore, many of our cases involve complex factual issues with massive records.  No case is too large for us to handle.

Our tax controversy group includes former Internal Revenue Service and U.S. Department of Justice federal tax litigators.  We believe the insights gained from our previous first-chair, government tax litigation experience enhances our ability to achieve favorable results for our clients.

Because the Internal Revenue Service uses its lawyers during the audit process to identify issues, draft document requests and interview key corporate officers, our clients often bring us on board during the audit to help them develop strategies to address both issues already raised as well as potential issues.  We often assist clients in developing responses to requests for information and to specific audit adjustments proposed by IRS agents. 

With our assistance, clients frequently resolve issues at the audit level.  We successfully settle most issues at appeals after presenting our client’s position in a persuasively written protest.  One thing is certain at both of these administrative levels:  where the IRS believes the taxpayer is prepared to litigate with a reasonable chance of success, favorable settlements are more likely.  Thus, our ability to achieve results at the administrative level is enhanced by our ability and experience in the tax litigation arena.

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Tax Client Services

McDermott Will & Emery

McDermott Will and Emery