Taxpayers trust Alston & Bird with U.S. and international tax issues during all phases of a tax dispute, including audits, administrative appeals, trial and appellate litigation at all levels of the federal court system, and mediation of both docketed and nondocketed cases.
Tax controversy is a highly technical and specialized area of legal practice, so you shouldn’t have to rely on general litigators. Our clients have benefited from our team of true tax litigators who have extensive, substantive command of income, estate, gift, and employment taxes. Our controversy attorneys bring to bear their knowledge of the complex procedural options of tax law to effectively defend client positions through written and oral advocacy.
When facing tax controversy, you need a team with broad experience in behind-the-scenes assistance in strategizing and responding to audit information requests in a way that best reflects the merits of your position. You want someone who can preserve the attorney-client, work product, and other applicable privileges. We also have extensive experience with special procedures such as summons enforcement proceedings, requests for technical advice, closing agreements, and fast-track and accelerated issue resolution. On your behalf, we interact with the IRS revenue agents and field specialists, including ISP specialists, engineers, employee benefits specialists, and international specialists.
Our advocacy for our clients focuses on the administrative appeals phase of a tax dispute. We campaign for your best interests by being actively involved in the oral and written justification of your position. We are trusted to lead negotiations with the IRS appeals officer and technical guidance coordinator to determine whether the dispute can be favorably resolved without litigation.
If the dispute cannot be resolved administratively, you need an experienced team to strategically select the logical forum for litigating the tax dispute. We have litigated cases in the U.S. Tax Court, U.S. district courts, bankruptcy courts, and appellate courts around the country. We also have settled or mediated cases after they were docketed for litigation.
Our clients value our ability to evaluate the big picture—we consider and understand the payment of tax, trial location, judges, government attorneys, timing and nature of the trial, settlement authority, publicity of proceedings, evidentiary rules, procedural rules, appellate jurisdiction, and judicial precedent.
Click here to learn more about our experience with controversy and litigation on the state level.