Federal Tax Controversy
Sidley’s Federal Tax Controversy practice represents clients at all stages of the administrative process, from audit through administrative appeal and post-appeals activities, and at every judicial level, from trial court to the United States Supreme Court. We also work with clients during the implementation of transactions and after implementation, but prior to audits, to ensure that their positions are well-documented and supported, that their files are maintained properly, and that the applicable evidentiary privileges have been established and protected.
Our practice is heavily focused on IRS examinations and IRS Appeals-level work, including the various alternative dispute resolution tools that the IRS makes available to taxpayers. In recent years, we have resolved many industry issues on favorable terms before the dispute has been docketed with a trial court. Nonetheless, because we are experienced litigators, we work through the administrative process with an eye on how decisions made there might impact potential litigation, so that our clients have the best possible chance to prevail in court, if litigation is necessary.
For disputes that we are unable to resolve administratively with the IRS, and for clients that retain us after exhausting their administrative 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 cases are docketed, we have a team of experienced tax litigators who prosecute the claims through trial and, if necessary, appeals. At the same time, we remain vigilant in looking for opportunities to resolve matters with government lawyers before trial whenever possible. We pride ourselves on our ability to make complex tax concepts comprehensible to decision-makers less familiar with the intricacies of particular subject areas in the tax code. Our lawyers have experience litigating tax disputes in all three tax trial forums, the various U.S. Circuit Courts of Appeal and the United States Supreme Court.