Tax Controversy
Sidley’s Federal and State Tax Controversy practice provides thoughtful and experienced advocacy on behalf of clients in federal and state tax disputes nationwide. We represent clients at all stages of the administrative process, from audit through administrative appeal, and at every judicial level, from local trial courts to the United States Supreme Court. A particular focus of our practice is favorably resolving disputes without litigation. In litigated matters, we bring to bear a team of experienced litigators and tax lawyers. Sidley’s Tax Controversy lawyers have an in-depth understanding of tax matters arising in controversies affecting particular industries, most prominently the banking, food processing, hedge fund, insurance, telecommunication, transportation and utility industries. Most recently, we have been regularly assisting clients with FIN 48 analyses.
Recent Federal Tax Controversies
- Representation of Coltec Industries Inc. in filing a writ of certiorari with the U.S. Supreme Court with respect to certain matters regarding the determination of the economic substance of a transaction
- Representation of Tyson Foods, Inc. in a Tax Court case, involving inventory accounting issues
- Representation of one of the nation’s largest pension plans in an Internal Revenue Service Audit CAP proceeding
- Representation of other large, publicly-traded corporations in a variety of disputes before the Internal Revenue Service Appeals Division with several hundred million dollars at stake, including research credit claims and a number of industry-specific issues
- Representation of a number of hedge funds in connection with ongoing income tax audits
Recent State Tax Controversies
- Representation of ANR Pipeline Company in filing a writ of certiorari with the U.S. Supreme Court from a decision of the Louisiana Court of Appeals regarding equal protection and due process rights of interstate pipelines
- Representation of Commonwealth Edison Company in municipal utility tax litigation
- Representation of U.S. Cellular in Missouri municipal telephone tax litigation
- Representation of Allstate Insurance Company in Illinois income tax litigation
- Representation of Sun Life Assurance Co. of Canada in the Illinois Supreme Court in retaliatory tax litigation
- Representation of Allstate Insurance Company in Wisconsin retaliatory tax litigation
- Representation of clients in audit and administrative proceedings in various states
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