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Tax Controversy

Resolving high-stakes tax disputes.

Our tax controversy team brings substantive experience and knowledge to every civil and criminal tax proceeding it handles, including voluntary disclosures, audits, IRS investigations, administrative appeals, negotiated settlements and trials. To avoid the expense and uncertainty of protracted litigation, Husch Blackwell trial attorneys share their perspective at the very beginning of a case to help the team strategize. Our creative and practical solutions have resulted in significant concessions from the IRS and many victories.  
 
Our tax controversy team of attorneys strives to obtain resolutions in confidential forums, but when necessary, our attorneys are aggressive trial advocates. Many have served with the federal government, giving them valuable insight into how the “other side” thinks. Our team includes former IRS attorneys, assistant U.S. attorneys, FBI agents, Department of Justice (DOJ) attorneys and a former U.S. attorney. 

Related areas of focus:

Our civil tax controversy guidance to clients includes:

  • Midco/intermediary transactions
  • Economic substance/business purpose doctrine
  • Section 385
  • Worthlessness of debt
  • Valuation
  • Repair versus capitalization
  • Purchase price discount
  • Method of accounting change
  • Tax credit issues, including new jobs credits and R&D tax credits
  • Net investment income
  • Section 269
  • Choice of entity
  • Consolidated return
  • Section 6901/transferee
  • Passive activity loss
  • At risk
  • Sham transactions
  • QLIP
  • Charitable contributions of inventory
  • Like-kind exchange
  • Personal versus business goodwill
  • Payroll
  • Penalties (e.g., civil fraud, substantial understatement valuation related penalties and reasonable cause defenses)
National Tier 1 in Tax Law.
Our group is recognized for excellence