Transfer Tax Controversy and Litigation

We are nationally recognized for our leadership and experience in representing taxpayers in estate, gift and generation-skipping transfer tax controversies against the IRS, especially those involving sophisticated transfer tax planning or difficult-to-value assets, such as interests in closely held businesses, family limited partnerships and limited liability companies. We have represented taxpayers against the IRS in many of the most significant contested transfer tax controversies in the country. 

We represent taxpayers at all levels of the transfer tax controversy, including IRS audits, administrative appeals, and litigation. While most of our cases are resolved amicably at the administrative level, we have represented taxpayers in numerous contested cases of national importance in the U.S. Tax Court, U.S. District Court, the Court of Federal Claims and U.S. Courts of Appeal.

Given our team’s extensive experience in defending against IRS challenges, we are often brought in at the estate planning/tax return preparation stage to assist the client and the client’s estate planning team in structuring and reporting the transaction to avoid or best prepare for a potential dispute with the IRS. Our team has developed a heralded skill in the area of advanced asset transfer techniques as well as the defense of those techniques against IRS challenges.



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