Tax Controversies

Alston & Bird has a national tax litigation and controversy practice representing taxpayers on both domestic and international tax issues from audit and administrative appeals to mediation, trial and appeals.  Because our litigators are both trial lawyers and tax lawyers, they bring substantive tax expertise to every matter, resulting in an outstanding track record of success in helping our clients favorably resolve their tax disputes.     

EXPERIENCE

The group's lawyers have litigated more than 80 cases before the U.S. Tax Court, the U.S. Court of Federal Claims, the federal district courts and the various federal circuit courts of appeals.  The group also has represented taxpayers in countless proceedings before the IRS Exam and Appeals Divisions throughout the country and is intimately familiar with all of the special IRS programs involving early or alternative dispute resolution procedures.  In the international tax area, the group is very active in both the Advance Pricing Agreement and Competent Authority programs, having represented clients in over 40 such matters. 

THREE CORE PRINCIPLES

Our philosophy and approach to tax litigation and controversy is based on three core principles.  First, we recognize that litigation is uncertain and expensive and that taxpayers prefer to settle their cases as quickly and efficiently as possible, consistent with a fair resolution.  To this end, we independently analyze each case and provide results-oriented advice as to the best course of action.  Second, we understand that, in some cases, litigation is unavoidable or the preferred resolution method because of the nature or importance of the issue or the IRS stance on a particular issue.  In such cases, we believe that the best results can be obtained by the early involvement of and thorough preparation by an experienced team of tax litigators working in close concert with the client.  We commit all of our varied resources and bring all of our experience to bear in an effort to achieve a successful outcome.  Third, unlike many firms, we believe that tax litigation is best conducted by lawyers who have a substantial background in the substantive tax law and first-hand experience with the procedural and evidentiary rules needed to effectively navigate in a courtroom.  This melding of the substantive, procedural and evidentiary is essential in developing and presenting the most effective and persuasive case.  As a result, the lawyers in our group are tax lawyers who can litigate.

RECOGNITION

We have developed an international reputation for excellence.  Our lawyers consistently have been recognized by their peers, bar associations and professional organizations for their expertise and accomplishments.  For example, eight of our lawyers have been listed in the The Best Lawyers in America, seven have chaired committees of the ABA Tax Section, and five have been elected to the American College of Tax Counsel. 

WINNING EDGE

A great result isn't everything; it's the only thing.  We believe that our philosophy, approach and experience can provide our clients with the winning edge.