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Capabilities / Tax Controversy

Tax Controversy

Resolving high-stakes tax disputes and controversy.

Our Tax Controversy law team brings substantive experience and knowledge to every civil and criminal IRS tax proceeding it handles, including voluntary disclosures, audits, IRS investigations, administrative appeals, negotiated settlements and trials. To avoid the expense and uncertainty of protracted litigation with the IRS, Husch Blackwell Tax Controversy trial attorneys share their perspective at the very beginning of a case to help the team strategize. Our creative and practical solutions have resulted in significant concessions from the IRS and many victories.  
Our Tax Controversy team of attorneys strives to obtain resolutions in confidential forums, but when necessary, our attorneys are aggressive trial advocates. Many have served with the federal government, giving them valuable insight into how the “other side” thinks. Our Tax Controversy law team includes former IRS attorneys, assistant U.S. attorneys, FBI agents, Department of Justice (DOJ) attorneys and a former U.S. attorney.

Our civil tax controversy guidance to clients includes:

  • Midco/intermediary transactions
  • Economic substance/business purpose doctrine
  • Section 385
  • Worthlessness of debt
  • Valuation
  • Repair versus capitalization
  • Purchase price discount
  • Method of accounting change
  • Tax credit issues, including new jobs credits and R&D tax credits
  • Net investment income
  • Section 269
  • Choice of entity
  • Consolidated return
  • Section 6901/transferee
  • Passive activity loss
  • At risk
  • Sham transactions
  • QLIP
  • Charitable contributions of inventory
  • Like-kind exchange
  • Personal versus business goodwill
  • Payroll
  • Penalties (e.g., civil fraud, substantial understatement valuation related penalties and reasonable cause defenses)

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