Tax Controversy and Litigation

Dorsey’s national and well-respected Tax Controversy and Litigation group represents individuals, businesses, Indian tribes and other governmental entities, and nonprofit organizations in all phases of federal, state, and tribal tax controversies, including audits, administrative appeals, alternative dispute resolution, litigation, and collection actions. Our controversy and litigation team is led by experienced tax lawyers and seasoned litigators who have formed strong working relationships with IRS and state department of revenue auditors, appeals officers, and counsel. The depth of our substantive and procedural capabilities allows us to successfully represent clients in all major tax areas and in all administrative and litigation forums.

Our areas of federal tax controversy and litigation expertise and experience include:

      • Income tax for individuals and businesses
      • Employment and withholding tax and information reporting, including employer and employee issues and worker classification reviews
      • Estate, gift and generation-skipping tax, including valuation-centered controversies
      • Tax issues relating to cooperatives
      • Tax issues relating to Indian tribes, tribal entities, and tribal members
      • Tax-exempt entities
      • Tax-exempt bonds
      • Excise taxes
      • Voluntary disclosures, including FBAR and Section 3520 disclosures
      • Criminal tax fraud and related issues
      • Innocent spouse relief
      • Trust fund recovery penalty
      • Private letter rulings and other practice before IRS National Office
      • Alternative dispute resolution options, including pre-filing agreements, Fast-Track Appeals resolution, Post-Appeal mediation, and other IRS practices and programs
      • Collection matters, including collection due process hearings, offers in compromise, installment payment agreements, penalty abatement requests, and issues relating to federal tax liens and levies and bankruptcy

Our areas of state tax controversy and litigation expertise and experience include:

      • Individual income tax, including residency inquiries and taxation of non-residents
      • State income tax withholding and reporting issues and worker classification inquiries
      • Corporate income and franchise tax, including nexus and apportionment issues
      • Occupation tax
      • Sales and use tax
      • Real property transfer/deed tax
      • Cigarette, tobacco, fuel and other excise taxes
      • Voluntary disclosure agreements
      • Innocent spouse relief
      • Personal liability for trust fund taxes
      • Collection matters, including penalty abatement requests, liens, and levies