Tax Controversy and Litigation

Covington’s tax controversy lawyers recognize that lengthy and contentious tax proceedings are rarely in a client’s interest. We draw upon our creativity and deep understanding of the IRS administrative and tax litigation systems to efficiently resolve tax controversies in as favorable and efficient a manner as possible. We recognize that the impact of tax controversies affects not only our clients’ bottom line, but also their operations, long term strategies, and public corporate image. We take all of these factors into consideration when developing a strategic approach to any contentious tax matter. These efforts are backed-up by our strong tax litigation team, who use a variety of litigation forums to ensure that our clients’ positions are upheld under the law.

Capabilities 

• Performing risk assessments to prepare for and mitigate lengthy audits
• Assisting in developing “audit ready” files related to critical transactions
• Developing strategic approaches to audits that limit further controversy by advising on substantive and procedural matters, including IDR responses, AOF requests, IRS interviews, statute extensions, work plan meetings, and NOPAs
• Drafting protests for, making presentations to, and negotiating settlements with the IRS Independent Office of Appeals
• Conferring with and obtaining guidance from the IRS National Office in the form of private letter ruling requests, automatic and non-automatic accounting method changes, technical advice memoranda, and pre-filing agreements
• Preparation for tax litigation in order to develop the best facts, narrative, and legal positions in advance of filing in court
• Representing clients in criminal tax investigations and proceedings
• Litigation in a variety of forums, including the U.S. Tax Court, Court of Federal Claims, federal district courts, and state courts
• Advising on, and drafting appellate briefs, and arguing tax cases before federal and state appellate courts