King & Spalding’s tax litigators have tried over 60 tax cases to verdict. Our tax litigation group is comprised of a former IRS Chief Counsel, a Chambers ranked litigator, and several former Department of Justice tax litigators. They have tried cases in the U.S. Tax Court, the Court of Federal Claims, and Federal District Courts. They also have substantial experience with appeals of tax cases to the U.S. Courts of Appeals and the U.S. Supreme Court, including a recent victory before the Supreme court regarding the IRS’s interpretation of the foreign tax credit rules. More than $1 billion in asserted or potential tax adjustments, penalties, and interest have been at stake in our recent matters.
Our tax litigators draw upon deep experience to guide clients through all of the issues that arise during tax litigation. In addition to having litigated numerous substantive tax issues, they possess significant expertise with penalty actions, John Doe summonses, summons enforcement actions, and privilege and procedural issues (such as TEFRA partnerships) that often arise in tax litigation.
We strive to provide our tax litigation clients with advice and results that are strategic, practical, technically astute, creative, and cost-efficient. Our goal is to resolve all tax litigation matters as favorably and efficiently as possible, including, when appropriate, through alternative dispute resolution processes such as mediation. King & Spalding’s tax litigation practice combines our substantive tax knowledge with the tax litigation experience of the firm’s accomplished trial lawyers to achieve optimal results.