Tax Controversy and Litigation

Ramsbacher Prokey Leonard LLP has a decades-long history of successfully representing clients in tax audits, appeals, controversies, and litigation with both federal and state taxing authorities.

Our approach to communication with the Internal Revenue Service often lends itself to a cooperative, cost-effective resolution of tax controversy matters. When negotiated resolution is not possible, Ramsbacher Prokey Leonard LLP has the experience to litigate before the U.S. Tax Court or other appropriate federal court. Our firm has historically focused on complex estate and gift tax controversies involving family limited partnerships, valuation issues, and the multifaceted implications of trusts and other legal entities. However, our firm also represents clients in connection with income and property tax matters.

Tax controversy and litigation may include assistance in the following areas:

  • Developing tax issues, facts, and documents relevant to the case, including all procedural facets of the matter
  • Filing administrative protests with the relevant taxing authorities
  • Representing clients before IRS Examination and Appeals
  • Where litigation is required, preparing pretrial discovery, post-trial briefs, and other filings with the court
  • Representing taxpayers on appeal, if necessary
  • Securing expert testimony and reports to develop persuasive and defensible support for the client’s position
  • Managing IRS collections, which may include preparing requests for abatement, seeking waiver of penalties, and securing IRS payment plans
  • Using the Freedom of Information Act (FOIA) to obtain valuable information in building a client’s case