King & Spalding is a national leader in representing clients in high-stakes tax disputes. We have achieved impressive victories in Federal, state and administrative settings. Our lawyers draw upon deep experience to guide clients through all of the issues that arise during the IRS examination and administrative appeals and the litigation phases of tax disputes. We strive to provide our tax litigation clients with advice (and results) that are strategic, practical, technically sound, creative and cost-efficient.
We have extensive recent experience defending clients against the IRS' vigorous attacks on alleged tax shelters. More than $1 billion in asserted or potential tax adjustments, penalties and interest are at stake in our current matters. Our expertise and experience covers all facets of tax controversy resolution, from audit to appeals to competent authority relief to litigation when an acceptable settlement is not forthcoming from taxing authorities.
In the area of state and local taxation, we have handled litigation concerning ad valorem taxes, income taxes, sales and use taxes and estate taxes, including issues regarding unit valuation, going concern valuation, exemptions, equalization and constitutional defenses.
In addition to litigating a diverse array of substantive tax issues, we have significant experience in resolving privilege, penalty and tax procedural issues (such as TEFRA partnership audit rules) that often arise in tax controversies. Our goal is to resolve tax controversies as favorably and efficiently as possible, including through alternative dispute resolution processes such as mediation and the Advance Pricing Agreement program.
King & Spalding’s tax controversy practice combines our substantive tax knowledge with the tax litigation experience of the firm’s seasoned litigators to achieve optimal results.