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Tax Controversy

Clients trust us to represent them in high-stakes tax litigation, audits and investigations, including in federal and state courts and before the IRS.

Our tax litigators are widely recognized for their experience, innovative planning and understanding of business needs. We are sought out to handle matters in areas including partnership taxation, debt-equity issues, intercompany pricing, interest capitalization and allocation, accounting for bad debts, amortization of intangibles, deductibility of takeover expenses, and foreign tax credit issues.

We have represented our clients before federal courts (including the U.S. Court of Claims, the U.S. Tax Court and the U.S. Court of Appeals for the Federal Circuit) and state courts (including the New York Court of Appeals), as well as before federal and state agencies. We regularly negotiate settlements with the IRS involving billions of dollars of disputed taxes. We pursue administrative appeals in complex tax matters, and, where necessary, take cases to trial.

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