Tax Controversy

SouthBank Legal’s tax controversy practice is led by two attorneys who held senior positions in the Justice Department’s Tax Division, where they were entrusted with the government’s most high-profile and high-dollar cases. Francesca served as the Chief of the Appellate Section, and Nate served as one of two Senior Litigation Counsels in the section. Together, they have decades of experience litigating the full range of tax issues affecting large and small businesses, high-net worth individuals, and tax-exempt organizations. We offer clients the opportunity to work directly with experts who are skilled at identifying the pressure points in a tax dispute, thinking outside the box to craft the best legal arguments, and providing exceptional client service in a cost-effective manner. With our decades of government experience, we know how to work effectively with the IRS to resolve tax disputes as early as possible, whether in an IRS audit or an IRS Appeals protest. And when a dispute ends up in court, we draw upon our deep well of litigation experience and credibility with judges to present the best case possible. Collectively, we have briefed and argued over 100 tax cases, and we know what works and what doesn’t when litigating a tax case.

We are collaborative team players who strive to add value for clients. SouthBank Legal frequently litigates tax cases, whether refund cases or Tax Court petitions, that were handled by other attorneys or by accountants at the IRS level. We partner with other law firms on large cases, where we leverage our appellate expertise to provide strategic input on difficult legal issues, draft key motions and briefs, handle oral arguments at trial, and advise the legal team on critical issues to preserve for a potential appeal. As for handling appeals, we are one of the few law firms whose tax controversy lawyers are also appellate experts, with first-hand knowledge of how the government will think about and handle the appeal.

SouthBank Legal also can help clients considering a particular tax position to evaluate the risk that it will be challenged by the IRS and the likelihood of overcoming the challenge in court. Our years of litigation experience have given us unique insight into why tax problems develop and how the IRS and courts will react to them. We understand the complexities of the federal tax system and the steps clients need to take before a tax return or refund claim is filed to ensure their interests are fully protected. SouthBank Legal also can help if a client learns they are under investigation for a criminal tax violation. Working with our white-collar defense team, SouthBank Legal is well positioned to help with both the criminal issues and tax issues that arise in such cases.

We understand that disputes with the IRS are distressing and can be financially perilous. SouthBank Legal provides top-notch and targeted representation, no matter the stage of the dispute.