Tax Controversy
Barnes & Thornburg’s Tax practice advises taxpayers on planning for, resolving, and litigating federal, state, and local tax audits and controversies. We are skilled in the often difficult terrain associated with the tax controversy process. Our advice ranges from planning for and defending a tax audit to handling administrative appeals before the Internal Revenue Service and state and local tax authorities. In the event a tax controversy is not resolved by the administrative process, we litigate all related tax claims through trial and on appeal.
We represent multinational corporations, Fortune 500 companies, emerging companies, individuals, estates, family offices, and nonprofit organizations concerning the resolution of their tax issues.
We advise clients pre-controversy by identifying and mitigating tax risks as part of tax planning. We also counsel clients on tax procedures, including reporting and disclosure requirements, avoiding or abating tax penalties, privileges, summons enforcement proceedings and filing Freedom of Information Act requests with the Internal Revenue Service.
Using effective advocacy and litigation strategies, Barnes & Thornburg’s Tax practice has resolved tax disputes in federal and state courts, including the U.S. Tax Court.
Expanded Capabilities
In addition to the services described above, the practice represents clients in complex civil and criminal tax controversy matters involving the Internal Revenue Service, U.S. Department of Justice, and state and local taxing authorities. This includes handling voluntary disclosures, refund claims, ruling and determination letter requests, technical advice memoranda, levy and lien matters, transferee and nominee liability disputes, whistleblower claims, and third-party summons and subpoena responses. The practice also conducts internal investigations related to potential tax compliance issues, advises on employment and information reporting disputes, and represents clients in tax litigation before the U.S. Tax Court, federal district and appellate courts, the U.S. Court of Federal Claims, and state and local tribunals, with integrated support for penalty abatement, collection defense, and related white-collar and regulatory matters.