Federal Tax Controversy
Sidley’s Federal Tax Controversy practice represents clients at all stages of the administrative process, from audit through administrative appeal, and at every judicial level, from trial court to the United States Supreme Court. Consistent with the IRS’s emphasis upon “coordinated” industry issues, we focus upon controversies affecting particular industries, most prominently the banking, food processing, hedge fund, insurance, telecommunication, transportation and utilities industries.
Our practice is heavily focused on IRS examinations and IRS Appeals-level work, including the various alternative dispute resolutions tools that the IRS makes available to taxpayers. A particular facet of our practice is favorably resolving disputes without litigation. We believe that by resolving disputes at the earliest stage, we are able to provide our clients with favorable resolution of their tax dispute without the additional costs, distraction of internal resources and publicity that necessarily accompany any formal tax litigation. In recent years, we have resolved many industry issues on favorable terms before the dispute has been docketed with a trial court.
On disputes that we are unable to resolve at the informal levels of the IRS, and for clients that retain us after exhausting their informal settlement opportunities, we assist each client in selecting the appropriate trial court (the United States Tax Court, the United States Court of Federal Claims or the local U.S. District Court) for the client’s particular tax issue. Once docketed, we rely upon a team of experienced trial lawyers and tax professionals to either reach a favorable settlement with the government attorneys or prosecute the tax claims through trial and, if necessary, appeals. Our lawyers have experience litigating tax disputes in all three trial forums, the various U.S. Circuit Courts of Appeal and the United States Supreme Court.
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