Description
Represent and advise clients on federal, state, and international tax matters, including planning, compliance, audits, and controversies. Draft tax-related documents and opinions, structure transactions, and litigate tax disputes before the IRS, U.S. Tax Court, and other tribunals.
- • Advise clients on federal, state, and local tax implications of business transactions, investments, and compensation.
- • Interpret the Internal Revenue Code, Treasury Regulations, IRS guidance, and state and local tax rules for individuals and businesses.
- • Analyze the probable outcomes of audits, appeals, and tax litigation using precedent and administrative guidance.
- • Present and summarize tax matters before judges and administrative tribunals, including U.S. Tax Court.
- • Evaluate audit findings and develop strategies and legal arguments to resolve tax controversies.
- • Gather and analyze financial records and interview clients, accountants, and witnesses to ascertain relevant tax facts.
- • Represent clients before the IRS, state taxing authorities, and in federal and state courts.
- • Examine legal and financial data to determine the advisability of challenging assessments or filing refund claims.
- • Argue motions, meet with judges, and examine witnesses during tax hearings and trials.
- • Present documentary and expert evidence in administrative and judicial tax proceedings.
- • Research tax statutes, regulations, court decisions, revenue rulings, notices, and other guidance to determine ramifications for matters.
- • Prepare protests, petitions, legal briefs, tax opinions, and requests for private letter rulings; file appeals in appropriate courts.
- • Negotiate resolutions of tax disputes, including penalty abatements and settlement agreements.
- • Collaborate with corporate, estate planning, international tax, and accounting professionals to structure transactions.
- • Search and analyze public records and financial documents to establish tax basis, ownership, nexus, or residency.
- • Supervise tax paralegals and support staff.
- • Manage matter budgets, billing, and administrative functions related to tax practice.
- • Serve as taxpayer representative under power of attorney and manage communications with tax authorities.
- • Advise executors and trustees on estate, gift, and generation-skipping transfer tax filings and audits.
- • Assist with drafting, interpreting, and commenting on tax legislation and regulations.
- • Draft and review tax-related documents, including transaction agreements, disclosures, elections, and closing binders.
- • Negotiate tax indemnities, covenants, and allocation provisions in mergers, acquisitions, and other transactions.
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Last reviewed: Jan 2026