Tax Controversy

SouthBank Legal’s tax controversy practice is led by an attorney who spent years representing the government in high profile tax litigation involving millions (and at times even billions) of dollars, and who left the Justice Department as one of two senior level attorneys in the Tax Division’s Appellate Section. SouthBank Legal offers its clients the combination of a highly sophisticated understanding of the most complex tax issues, a developed talent for simplifying those issues into concise arguments, and a unique understanding of the motivations and thinking of the lawyers on the other side of the dispute. Those same abilities 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.

For clients facing an audit, or who have already received a notice of deficiency, SouthBank Legal can work to resolve issues with the IRS, including through the use of various IRS special dispute resolution programs (like Fast Track Settlement, Early Referral to IRS Appeals, and Post-Appeals Mediation). But SouthBank Legal’s attorneys are also comfortable litigating tax disputes in the U.S. Tax Court, the U.S. Court of Federal Claims, the U.S. district courts, and, on appeal, in the U.S. circuit courts. Additionally, SouthBank Legal represents clients who may have paid significantly more than they owe and now seek a refund – helping them prepare and file a refund claim and, if necessary, a refund suit.

We expect that the recent dramatic increase in the IRS’s tax enforcement budget will lead to many more audits and aggressive efforts to collect taxes in the coming years. Inevitably, the IRS will sometimes overreach. Whether the IRS has challenged a client’s income tax position, a client’s family’s estate planning, or even alleged a criminal tax fraud, SouthBank Legal is well positioned to help. In large tax cases, SouthBank Legal can also serve as a cost-effective co-counsel, often with the firm that structured the transaction at issue, to provide a fresh independent perspective. We are adept at working collaboratively with other attorneys to serve the client’s best interests. SouthBank Legal has particular expertise in tax issues affecting the cannabis industry and in conservation easement cases. Finally, SouthBank Legal provides superlative appellate representation in tax cases – both in cases we have handled at trial and in cases that were managed at the trial level by other attorneys. SouthBank Legal provides a wealth of appellate experience: the attorney who leads our tax controversy practice previously represented the government as lead appellate counsel in dozens of tax cases.