We are regularly called upon to astutely advocate on behalf of our clients and to solve
disputes with the Internal Revenue Service (IRS) and other relevant state and local taxing authorities.

We have extensive experience in representing clients during Audits and Examinations, and also before the -
 

• IRS Independent Office of Appeals, including in connection with Protests of proposed adjustments and requests for Technical Advice Memorandum (TAM)
   

• IRS Advance Pricing and Mutual Agreement (APMA) Program and the U.S.Competent Authority
   

• Various IRS Offices of the Associate Chief Counsel, including in connection with requests for a Private Letter Ruling (PLR or LTR)
   

• U.S. Department of the Treasury and the Financial Crimes Enforcement Network (FinCEN)
   

• U.S. Tax Court
   

Our extensive Tax Controversy Practice includes the following sub-components:

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