Tax Controversy

Overview

“Every individual I have met at Blank Rome is impressive. They are strong in all areas. They are my first choice as counsel and will remain so.”

— Client feedback, Chambers USA

With the IRS and state and local taxing agencies aggressively enforcing evolving tax laws, you and your organization are under closer scrutiny than ever. Audits are gaining in intensity and are becoming more intrusive and contentious, and taxing authorities are employing a variety of tools to assess and collect taxes and impose penalties for non-compliance. They may even go as far as criminally prosecuting egregious violators of the tax laws. The pressure is on—whether you are facing an audit, tax litigation, or a criminal investigation on the federal, state, or local level, you need experienced tax litigators to guide you through the tax controversy process

Blank Rome’s tax litigators have served as Assistant U.S. Attorneys, U.S. Department of Justice (“DOJ”) trial attorneys, Internal Revenue Service (“IRS”) counsel, U.S. Department of the Treasury (“Treasury”) officials, state and local government officials, and certified public accountants. Our team can provide you both the government perspective and sophisticated and technical tax experience and advice. We’ve handled all aspects of tax controversy matters, including administrative audits, appeals, collection matters, and litigation in the U.S. Tax Court, U.S. Court of Federal Claims, U.S. district courts, U.S. bankruptcy courts, and courts throughout the U.S. states and the District of Columbia. We help you navigate sensitive issues by developing comprehensive strategies that can either mitigate future risks or bring your issues to resolution.

How We Can Help

  • IRS audits, refund claims, and appeals
  • State, city, and municipal audits, and administrative appeals
  • Criminal tax investigations and prosecutions defense
  • Litigation in federal, state, and local courts
  • IRS collections matters
  • Corporate and individual income tax, sales and use tax, and transfer tax
  • International tax compliance
  • Foreign Bank Account Reporting (“FBAR”)
  • Foreign Account Tax Compliance Act (“FATCA”)
  • IRS Voluntary Disclosure for domestic and offshore accounts
  • Bank Secrecy Act and USA Patriot Act
  • Compliance with tax bulk sales laws

What Sets Us Apart

  • The group includes former federal, state, and local government officials from the IRS, the DOJ, the Treasury, and state and local agencies who have strategic relationships within Congress and who have presented before the Senate Finance and House Ways and Means Committees.
  • Our prominent state + local tax (“SALT”) team includes attorneys who pioneered the nationwide practice of SALT and have been involved in many of the most ground-breaking SALT cases decided over the last 30 years.
  • Members of Blank Rome’s tax group have previously served as CPAs and members of “Big Four” national tax practices.

Experience

  • Ongoing representation of numerous real estate partnerships in connection with the acquisition and operation of residential properties.
  • Ongoing representation of a real estate developer in connection with the proper accounting method for inventory sales.
  • Ongoing representation of an estate in U.S. Tax Court litigation challenging the IRS’s disallowance of charitable contribution and assertion of fraud penalty.
  • Ongoing representation in connection with bank shares tax refund claims.
  • Ongoing representation in connection with litigation involving sales tax refund on electricity.
  • Representation of a former chairman and chief executive officer of a public company in securities, accounting, and tax fraud prosecution and related civil matters in U.S. Tax Court.
  • Representation of a clinical laboratory owner in connection with investigation and prosecution for tax and health care fraud, and related civil issues involving IRS collections.
  • Representation of a business owner in federal prosecution for public corruption and related tax offenses.
  • Representation of several individuals in connection with IRS and DOJ investigations and prosecutions relating to the failure of reporting bank accounts in Switzerland, and subsequent audits by the IRS.
  • Ongoing representation of a foreign bank on compliance issues relating to FATCA.
  • Successfully enrolled numerous individuals in the IRS offshore voluntary disclosure programs relating to undisclosed bank accounts.