Tax Controversies

Schiff Hardin tax lawyers have handled all manner of federal, state and local tax controversies on behalf of the firm's clients. We have been engaged to:

• Consult with our clients or their accountants at the audit level
• Conduct administrative appeals proceedings
• Represent our clients in tax litigation, when necessary

Tax controversies with which we have been involved include:

• A diverse array of tax accounting and amortization issues raised in connection with business acquisitions and operations
• Unreasonable compensation and unreasonable accumulation of earnings challenges
• Challenges to sophisticated capital formation structures such as the use of leveraged preferred stock
• Challenges to straddle and other trading strategies

We also have represented a number of individuals and entities at the audit level and beyond in connection with so-called "tax sheltered investments." Working with attorneys in the firm's White Collar Crime group, we also represent clients in connection with tax fraud investigations and litigation.

Our attorneys represent taxpayers involved in tax collection and related matters. We counseled corporate officials regarding the attempted imposition of the "100% penalty" for the payment of payroll taxes not properly paid by failed or failing corporations. We also have represented "innocent spouses" in connection with the attempts of the Internal Revenue Service (IRS) to collect taxes owed by their former spouses. We have assisted taxpayers who have fallen behind in their tax payment responsibilities in reaching installment payment agreements for the satisfaction of back taxes.

In addition, Schiff Hardin attorneys represent individuals and fiduciaries in disputes with the IRS concerning:

• Federal estate, gift and generation-skipping tax
• Individual fiduciary and income tax
• Taxation of family business entities.

We include among our attorneys former IRS and Department of Justice personnel who can assist at all stages of tax controversies from initial audit through contested court proceedings, if necessary. We have an excellent track record of resolving tax controversies privately and favorably to taxpayers.