Commercial Litigation Group

Tax Litigation

State and Local Tax Controversies.  Butler Snow regularly represents multi-state and out-of-state taxpayers in disputes with state and local taxing authorities, both in opposing assessments and seeking refunds. The firm handles the administrative review process, and pursues appeal to state court when necessary. Employing the knowledge of the firm’s tax lawyers and the experience of its litigators in the tax arena, Butler Snow handles a variety of SALT issues. Recent cases have involved taxation of electronic commerce and wireless telecommunication service, determination of apportionable income and other corporate income and franchise tax issues, gaming taxes, sales and use tax matters, real and personal property tax disputes, and others.

Federal Tax Litigation.  The firm’s tax team regularly represents clients in negotiating reductions in proposed assessments with the IRS on a wide variety of federal taxes and tax issues. Butler Snow handles federal tax cases both in the U. S. Tax Court and in federal district courts, utilizing the talents of its tax lawyers and creative litigators. Butler Snow has been particularly active in the estate and gift tax area, with cases involving valuation of minority, fractional, and controlling interests in closely held corporations, improper assessment of penalties, discounts for undivided interests and conservation easements in real property, and similar issues.

Criminal Tax Litigation.  The firm's White Collar Crime and Government Investigations Group represents clients who have become the focus of possible criminal tax violations, assisting the client both in the investigative and prosecution stages.  Recent cases have involved IRS and Department of Justice investigations into tax shelters and alleged tax return violations in the Virgin Islands, Washington, D.C., and New York City. This Group has former federal prosecutors who are well-experienced in litigation involving criminal tax matters.

For additional information on Tax Litigation, please contact J. Paul Varner (tax), Robert M. Frey (litigation), J. Stevenson Ray (litigation) or James B. Tucker (criminal tax litigation).

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