Charitable Donations

Our attorneys have over 50 years of combined experience with the tax deduction for charitable contributions. Our practice handles federal tax issues, and we serve clients nationwide. Our attorneys have served as “subject matter experts” at the Internal Revenue Service (IRS) and we have decades of experience training IRS attorneys and revenue agents in charitable deductions, penalties, and other federal tax matters. Our attorneys have been key players and advisors in writing and interpreting regulations and managing litigation teams. We are ready to provide you with legal advice on tax issues related to charitable donations, including contemporaneous written acknowledgments, Forms 8283, deeds, appraisals, and baseline documentation reports.

If you are donating cash, cash equivalents, or any type of property, including conservation easements, let's talk.

Tax Controversy –

IRS DISPUTES

We have significant experience in tax administrative practice and procedure. Our practice handles federal tax issues, and we serve clients nationwide. For decades, we have worked closely with revenue agents during audits, including the IDR (information document request) process, notices of proposed adjustments/revenue agent reports (also called the 30-day letter), statutory notices of deficiency/the “90-day” letter, notices of final partnership administrative adjustments (FPAAs in TEFRA cases), and notices of final partnership administrative adjustments (as well as FPAAs in BBA cases), summonses and summons enforcement, fast-track mediation, and consideration by IRS Appeals.

We have significant tax experience with domestic and international tax issues and civil tax penalties. Those issues span a wide area of subject areas affecting individuals, partnerships, and corporations.

If you receive a letter from the IRS, let’s talk.

Tax Controversy –

LITIGATION

We have intensive experience in tax litigation and litigation support. Our practice handles federal tax issues, and we serve clients nationwide. We regularly litigate cases in U.S. Tax Court, as well as have had intensive involvement on significant tax cases litigated by the U.S. Department of Justice in U.S. District Court and the U.S. Court of Federal Claims. We develop litigation strategy, prepare and respond to discovery, document management, settlement discussions, exhibit management, expert witnesses, pretrial motions, pretrial memorandum, and writing and reviewing post-trial briefs. The case types include partnership cases (TEFRA/BBA), deficiency cases of corporations and individuals, whistleblower cases, collection due process cases, and innocent spouse cases.

We also can assist as co-counsel in your case and help you assist your client with your case.

If you want to litigate a tax case in federal court or need assistance with the case you are litigating, let’s talk.

Civil Tax Penalties

For over a decade, we have provided legal advice and developed and presented training to IRS attorneys and IRS revenue agents nationwide regarding civil tax penalties (including civil tax penalties under §§ 6662, 6662A, 6663, 6664, 6676, 6694, 6695A and first-time abatement). Because our practice deals with federal tax issues, we accept clients nationwide. We have significant experience with the requirements regarding reportable transactions (including listed transactions) and Form 8886, “Disclosure Statements,” as well as disclosures on Form 8918 for “Material Advisors.” 

If you are concerned about a civil penalty or disclosures, let’s talk.