Find Lawyers in Tampa, Florida for Litigation and Controversy - Tax
Practice Area Overview
Tax litigation and controversy broadly describes the practice of resolving tax disputes with federal, state, local, and foreign tax authorities. A tax controversy may involve a business (whether for-profit or not-for-profit), trust, estate, or individual, and can result from any form of taxation, including income tax, estate and gift tax, state sales and use tax, or local property tax. In general, tax disputes are separated into civil and criminal matters.
Attorneys specializing in tax controversies may assist a taxpayer in a civil matter by providing expertise regarding substantive tax laws, dealing with revenue agents, formulating audit strategies, and pursuing administrative or judicial appeals. Although litigation is usually the option of last resort for most taxpayers, an experienced attorney can provide skillful representation in court proceedings. A tax attorney can play a leading role in resolving a tax controversy or simply serve as an advisor to the taxpayer or his or her accountant. In addition, an attorney may assist the taxpayer in planning transactions to avoid future disputes.
Civil tax matters usually begin with audit, assessment, and collection activities by a taxing authority. Alternatively, a controversy may be initiated by a taxpayer claiming a refund. At the federal level, resolving a civil tax controversy may require discussions with the IRS, a written appeal to and discussions with the Appeals Office, or, potentially, litigation in the United States Tax Court, District Courts, or Court of Federal Claims. After litigation of a case in a lower court, the taxpayer may have appeal rights in the federal appellate courts. A similar process is available in resolving civil tax controversies at the state and local levels.
An international tax attorney may assist a taxpayer in resolving issues with taxing authorities in foreign jurisdictions or involving issues arising in international transactions, including advanced ruling requests to achieve tax certainty and penalty protection, competent authority requests to resolve treaty issues, advanced pricing agreements to resolve transfer pricing issues, and using voluntary disclosure programs to prevent or reduce tax penalties.
Criminal tax matters involve taxpayers alleged to have evaded taxes or otherwise willfully violated the tax laws. Tax litigators can assist such taxpayers by representing them during criminal investigations by the IRS, the Justice Department, or state taxing authorities, and in criminal trials, sentencing proceedings, and appeals.
Jenny L. Connors, Associate John S. Davis, Partner Williams Mullen
Corporate Law & Commercial Litigation Legal Guide 2023View Legal Guide
Edward F. Koren is a partner in Holland & Knight's Tampa and Lakeland offices and leads the firm's Private Wealth practice. His practice is focused on wealth planning and protection for entrepreneurs and multi-generational business owners and serves clients across the country. Mr. Koren is past chair of the American Bar Association's Real Property, Probate and Trust Law Section; former American College of Trust and Estate Counsel Regent and past chair of its Estate and Gift Tax Committee;...
Jack A. Levine has been with Holland & Knight since 1981. His areas of practice include business and tax planning, and structuring of corporate acquisitions and reorganizations, partnerships, limited liability companies, syndications and joint ventures. Mr. Levine also practices in the tax controversy area, the utilities taxation area, and in several other tax and tax-related areas. Mr. Levine is Board Certified in Tax Law by The Florida Bar. From 1977 to 1981, Mr. Levine worked in the Na...
Chris utilizes his extensive tax and accounting background to assist high-net-worth individuals and closely held businesses with establishing and implementing sophisticated wealth transfer strategies, charitable planning, and business formation and restructuring. He also has extensive experience in tax controversy, the purchase, sale and operation of private aircraft, and tax planning for real estate transactions. Given the personal nature of his work, Chris takes the time to understand each ...
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