Efficiently resolving every type of tax-liability dispute
Butler Snow’s Tax Controversy team has experience with successfully resolving high-stakes, complex tax controversies through litigation, but most of our successes are achieved more privately through administrative hearings or other low-key approaches.
We routinely represent clients regarding tax issues arising from audits by the IRS and state tax authorities. Our tax attorneys represent clients in administrative hearings at all levels of the IRS and state departments of revenue.
While our goal is to resolve even the most contentious disputes in an expeditious manner, sometimes tax disputes end up in court. If the matter cannot be settled on terms favorable to the taxpayer, we litigate in the United States Tax Court and in state courts. Our litigation team provides experience rooted in our deep understanding of tax law—at all levels of government.
Butler Snow’s Tax Controversy team has an established reputation for deep experience across industries and with a variety of types of tax controversies. Given our broad experience representing clients in complex taxation matters, we can provide clients with knowledgeable, innovative and industry-specific solutions, no matter the tax issue they have encountered. The collaborative nature of our firm’s culture helps ensure that we can assemble a tailored team with the tax experience you need.
Highlights
- Representation of a Fortune 500 company in a multi-million-dollar income tax assessment and refund action in Mississippi Chancery Court resulting in a $4 million refund. The issue in question was whether gain on the sale of a business was business income or nonbusiness income under the Uniform Division of Income for Tax Purposes Act (UDITPA).
- Representation of a Fortune 500 company in an income tax assessment of more than $1 million from the disallowance of royalties paid to an affiliate for the use of the affiliate’s intellectual property.
- Representation of a multi-state corporation seeking a refund of state-use taxes pursuant to an exemption based on the payment of sales tax to another state on the same transaction.
- Representation of taxpayers in U.S. District Court to contest transferee liability for unpaid gift taxes.
- Representation of taxpayers before the IRS Appeals Division to defend discounts claimed in connection with the valuations of gifted interests in family limited partnerships.
- Representation of an estate in U.S. Tax Court to contest the disallowance of a charitable deduction for a post-mortem grant of a conservation easement.
- Representation of taxpayers before the IRS Appeals Division and the U.S. Tax Court to contest proposed assessments of income tax.
- Representation of a multi-state corporation in Mississippi Chancery Court contesting the disallowance of deductions for premiums paid to a captive insurance company.
- Representation of a multi-state corporation in Mississippi Chancery Court involving the issue of how to apportion income earned from ecommerce.
- Representation of an out-of-state individual taxpayer in a multi-million-dollar Mississippi income tax assessment in which the taxpayer could not post jurisdictional bond. Relief was secured in TRO action in Mississippi Chancery Court resulting in a favorable settlement for the taxpayer of approximately 25% of the original assessment.
- Representation of an individual before the IRS and FBI accused of “structuring” bank deposits to avoid currency transaction reporting requirements. The successful representation ultimately led to the individual avoiding indictment.
