TAXATION - FEDERAL

We regularly advise a variety of entities and individuals, including corporations, general and limited partnerships, joint ventures, limited liability companies, sole proprietorships, and tax-exempt organizations, on federal taxation issues.  Our federal taxation practice is primarily concentrated in the following areas:  (1) advising individuals and businesses regarding their business operations and business transactions and (2) tax controversies.  We provide practical tax advice that is consistent with achieving the client’s goals.  If necessary, we will obtain a private letter ruling from the Internal Revenue Service regarding the tax treatment of a certain transaction.       

• Business formations—including choice of entity
• Taxable and tax-free mergers, acquisitions, and reorganizations
• Taxation of real estate and other property transactions   
• Taxation of executive/employee compensation  
• Business dissolutions/liquidations

With respect to tax controversies, we have represented clients in tax audits and dispute proceedings before the Internal Revenue Service and the U.S. Tax Court.  The controversy matters we have handled cover a wide array of issues, such as responsible person penalties, capitalization rules, reasonable compensation, tax-exempt bond anti-arbitrage rules, tax shelters (e.g., sham trusts and offshore deferred compensation schemes), and failure to file returns.  Having experience in both the tax planning and tax controversy areas allows us to advise clients regarding audit strategies prior to the filing of a return.

• Audit representation
• Appeals division representation
• Collection due process representation
• Preparation of offers in compromise
• Tax liens
• U.S. Tax Court and U.S. District Court