Find Lawyers in Annapolis, Maryland 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
Nick helps individuals and businesses with a variety of tax-related matters find relief through his efforts as a tax attorney. These include negotiations with the federal and state government agencies to adjust accounts and settle tax matters, criminal investigations, tax planning, and strategy development. His experience working at the Comptroller of Maryland gives him a distinctive outlook on corporate income tax, individual income tax, sales and use tax, withholding tax, and admissions and...
Peter Haukebo’s a Senior Associate at Frost Law. He concentrates his practice in the areas of tax controversy and planning and business transactions. Prior to joining the firm in 2018, he practiced at Chaney | Haukebo LLP. From 2013 to 2019, Peter served as an adjunct professor of law instructing in the Low Income Taxpayer Clinic at the University of Maryland Francis King Carey School of Law.
Kaitlyn’s experience as a Certified Public Accountant and a tax attorney give her a unique perspective on domestic and international tax compliance issues for individuals and businesses including streamlined compliance for individuals, corporations, partnerships, and limited liability companies. Kaitlyn handles cases with issues involving individual and corporate income tax, international tax compliance, IRS and State tax audits, tax relief and collection — including sales and use...
Michael is a director at Frost Law. His principal areas of practice include tax controversy, complex civil litigation and appeals, and white-collar criminal defense. In this context, he represents clients in various proceedings before the Internal Revenue Service, the U.S. Department of Justice, and the U.S. Attorneys’ Office. Prior to joining Frost Law, Michael was an attorney at a well-known regional law firm and a law clerk at the Circuit Court for Baltimore City. From those experien...
Eli utilizes his background as a CPA and attorney to vigorously defend clients before the IRS and state taxing authorities. Eli is also the firm’s lead on international tax matters, which involves complex international tax compliance issues, resolving many offshore voluntary disclosures and streamlined filing compliance procedures, as well as preparing complex Passive Foreign Investment Company (PFIC) computations. He also represents clients in a significant number of tax collection mat...
Rebecca Sheppard, Esq. is a tax attorney and a Director in the Tax Controversy practice group at Frost Law. Over the last two years, Rebecca has used her background in government practice to work with business clients across the country in helping them secure government funding from PPP, EIDL, and the Employee Retention Credit (ERC). Unlike many other tax professionals, Rebecca has used her tax and legal background to closely follow the legislative changes and relief programs, giving her a th...
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