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Perkins Coie tax controversy attorneys have collectively litigated hundreds of cases before the U.S. Tax Court, U.S. District Courts, U.S. Federal Court of Claims and state trial courts, efficiently and favorably resolving tax controversies. In addition, we regularly handle audits and appeals with the IRS and state and local taxing authorities.
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Successfully resolved gift and estate controversy matters, including the following:
Provide representation in various tax controversy cases in District Court and Tax Court, in addition to numerous audits that escalated through appeals but avoided trial.
Represent clients in cases involving IRS examination of income tax related issues associated with trade or business activities.
Advised on private equity vertical slice gift tax and gift and estate tax cases related to profit/carried interests and other interests in investment properties and related valuation issues.
Counsel clients in cases relating to the valuation of high net asset value assets with lower valuation as an on-going business, and coordinate strategy for disputes through court proceedings.
Manage cases involving partnership funding, transfer and administration with a focus on Chapter 14 IRC 2701 entities.
Advise in cases relating to sales of assets to grantor trusts with and without self-canceling installment notes.
Represent clients in cases involving loans to estates structured as “Graegin” loans with successful defense through IRS examination.
Counsel clients in passive activity loss cases under section 469 and hobby loss cases under section 183 of the Internal Revenue Code.
Advocated for clients involved in adjusted basis determinations for domestic and foreign real estate involving reconstructed or missing substantiation in a number of California and federal income tax disputes.
Represented clients in a matter that lead to securing a state estate refund of nearly $2 million for a client after 9 years of tax controversy with the IRS.
Acted in numerous penalty cases, including failure to pay penalties, failure to file penalties, accuracy-related penalties, fraud penalties and excise taxes, amongst others, by demonstrating reasonable cause.
Achieved case victory on willful Foreign Bank Account Report (FBAR) penalties before the United States District Court.
Secured Section 1031 victories before the California Franchise Tax Board involving “swap and drops” and “drop and swaps.” Represent various clients in desk audits of source of income and residency matters.
Served as lead counsel on ongoing litigation involving split-dollar life insurance arrangements.
Provided representation as lead counsel on ongoing litigation involving low-income housing development issues.
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