Tax Controversy

In each and every case, the goal of our Tax Controversy and Litigation Group is to resolve the client’s tax dispute as quickly and as advantageously as possible.  With that goal in mind, the members of the Williams Coulson Tax Controversy and Litigation Group deal regularly with the Internal Revenue Service (IRS), the Treasury Department, the Department of Justice, and state and local taxing authorities in resolving tax disputes.  When necessary, our attorneys also litigate tax disputes in the U.S. Tax Court, the Court of Federal Claims, and federal district and appellate courts and their state counterparts.

Our attorneys have represented clients in cases involving income taxes, payroll taxes (including trust fund recovery penalties), excise taxes, franchise taxes, estate and gift taxes, property taxes, sales and use taxes, reporting penalties, and related penalties and interest.

Our attorneys routinely represent clients at various stages:   

Administrative

Typical cases involve audit representation, refund claims, abatement requests, private letter ruling requests, audit reconsideration requests, and formal protests before the IRS or state appeals divisions. 

Litigation

Disputes that cannot be settled administratively are typically tried before the U.S. Tax Court, Court of Federal Claims, a federal district or appellate court, or their state counterparts. 

Tax Collection Defense

Typical cases involve negotiations of installment agreements and offers-in-compromise and representing clients at due process hearings, equivalent hearings, and at collection appeals.