Federal Tax Controversy & Tax Policy

Pillsbury's Federal Tax Controversy & Tax Policy practice is nationally ranked by 2012 Chambers USA, a leading independent guide that interviews clients to compile its rankings.

Chambers notes, "This highly regarded team is recommended for its innovative approach to federal controversy and litigation matters, as well as state and local tax."

Pillsbury’s federal tax controversy lawyers operate from a bench with deep and broad-ranging experience with tax disputes of every variety. Our team includes the former Assistant Attorney General for the Tax Division at the United States Department of Justice, as well as former IRS Chief Counsel and Department of Justice litigators. Our lawyers know from first hand experience how the government will view an issue from the standpoint of allocation of resources, strategy, settlement, publicity and policy. This vast reservoir of practical experience enables Pillsbury to obtain the best possible results for our clients in the most efficient fashion.

Our distinctive approach involves not only defending clients once they are involved in a dispute, but also counseling clients as they plan transactions to avoid tax disputes and representing them in letter ruling requests before the IRS. Our representation is tailored to the unique needs of our clients. In the case of large corporate clients with sophisticated in-house capabilities, our services may be limited to counseling client personnel on how to deal with one or a few particular issues that arise during audit. In other cases, including those involving partnerships, trusts, estates, individuals and other entities, we represent clients during the audit.

We have a wealth of experience in the IRS Appeals process and with alternative dispute resolution programs such as Fast Track Settlements and Mediation and Post-Appeals Mediation. In more than 75% of our cases, we are able to successfully conclude matters in the audit or Appeals stage. When a satisfactory resolution cannot be obtained at the administrative level, we are well-equipped to litigate the matter at both the trial and appellate level if necessary. Pillsbury’s lawyers have litigated hundreds of cases in the U.S. Tax Court, the U.S. District Courts, the U.S. Court of Federal Claims and the U.S. Bankruptcy Court. Our experience extends as well into the U.S. Courts of Appeals and the U.S. Supreme Court.

Our controversy lawyers also possess the deep technical knowledge needed to effectively advocate a client’s position and, whenever necessary, team with similarly qualified lawyers from our entire range of tax specialty practices.

We have successfully represented our clients in the full spectrum of federal tax controversy issues including transfer pricing, tax accounting, inventory capitalization, credits, corporate transactions, debt vs. equity, valuation, stock options and tax shelter defense. Our Employee Benefits lawyers also represent clients in qualified plan audits and advise on correction programs under the Employee Plans Compliance Resolution System.