Find Lawyers in San Antonio, Texas 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.
Civil Tax Controversies
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 Controversies
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
Chad Muller has more than 40 years experience in federal and state tax controversies. As a Department of Justice Trial Attorney and as an Assistant United States Attorney, Mr. Muller represented the government in the largest criminal tax prosecutions in the country. In 1975, he received the Department of Justice John Marshal Award for outstanding achievement in the trial of complex litigation. Representing taxpayers in civil and criminal tax matters since 1977, Mr. Muller has consistently ach...
Joshua Sutin helps clients unravel complex legal and business issues related to employee benefit plans, tax-exempt organizations, and business tax planning. He counsels both businesses and not-for-profit organizations on the full range of tax and employee benefits issues. Experience Qualified Retirement Plans. Joshua counsels clients regarding their qualified plans, including employee stock ownership plans (ESOPs), and advising on tax qualification of plans, fiduciary duty issues, Department ...
Mr. Vasquez concentrates his practice on federal, state, and international transactional and tax controversy matters, including income, employment, sales, franchise, motor fuels, tobacco, and other excise matters before the IRS and state taxing authorities. Mr. Vasquez has experience resolving IRS examinations, collection cases, installment agreements, offers in compromise, requests for collection due process hearings, private letter rulings and requests for innocent spouse relief. Mr. Vasque...
Leo Unzeitig is a senior associate in Chamberlain Hrdlicka’s San Antonio office. He assists with a wide range of federal tax controversy and litigation matters at all stages before the Internal Revenue Service and federal courts. Leo also advises on tax planning and transaction matters, including state and local tax issues. Leo is an adjunct professor at the University of the Incarnate Word teaching Tax Research. He also enjoys counseling taxpayers through the Tax Court Pro Bono Program...
Victor J. Viser is an associate in Chamberlain Hrdlicka's San Antonio office. He focuses his practice on federal, state, and international tax planning and controversy matters. Mr. Viser also has expertise on the Paycheck Protection Program, having coauthored articles on all aspects of the program for industry leading publications such as Bloomberg Tax, Houston Business Journal, Texas Tax Lawyer and Today’s CPA.
Recognition by Best Lawyers is based entirely on peer review. Our methodology is designed to capture, as accurately as possible, the consensus opinion of leading lawyers about the professional abilities of their colleagues within the same geographical area and legal practice area.
Best Lawyers employs a sophisticated, conscientious, rational, and transparent survey process designed to elicit meaningful and substantive evaluations of the quality of legal services. Our belief has always been that the quality of a peer review survey is directly related to the quality of the voters.