Our tax litigation approach combines our substantive knowledge of the applicable tax principles with our knowledge of the special assessment, determination and collection procedures applicable to tax cases, including the unique courts and tribunals involved in the process. Our tax litigators have tried cases before U.S. District Courts, the U.S. Tax Court and state courts and tax tribunals in the jurisdictions in which they are admitted to practice, and have taken cases to higher state and federal appellate courts, including the U.S. Supreme Court. (Commissioner v. Indianapolis Power & Light Co. 493 U.S. 203 (1990).
While most tax controversies are settled at the administrative level, either at an audit or intermediate appeals level, the record created at the administrative level will color the conduct of a court proceeding, should one materialize. We treat all of our tax controversies as having the potential for litigation.