Tax Controversy

Accountability and Compliance Solutions

The Internal Revenue Service (“IRS”) and state and local taxing agencies are enforcing tax laws more aggressively than ever before as a result of today’s volatile economic environment.  Audit rates are increasing, and taxing authorities are employing a variety of tools to assess and collect taxes, impose penalties for non-compliance, and in certain circumstances, to criminally prosecute egregious violators of the tax laws.  Due to these growing challenges, businesses and individuals need experienced tax counsel to guide them through the tax controversy process, whether it be an audit, tax litigation, or a criminal investigation.

Blank Rome is uniquely qualified to represent taxpayers in this field. The attorneys in our Tax Controversy Practice have served as Assistant U.S. Attorneys, Department of Justice trial attorneys, IRS counsel, Treasury Department officials, and certified public accountants, and can provide both the government perspective to clients as well as sophisticated, broad-based technical tax experience and advice.  Our attorneys have handled all aspects of tax controversy matters, including administrative audits, appeals, and collection matters, and litigation in the U.S. Tax Court, U.S. Court of Federal Claims, and U.S. district courts.  We successfully help our clients navigate sensitive issues and develop comprehensive strategies that have an impact on the bottom line for businesses and individuals alike.

What We Do

We provide clients with advice, counsel and representation in all aspects of federal, state and local tax matters. Specific areas of concentration include:

  • IRS audits, refund claims, and appeals
  • State, city, and municipal audits, and administrative appeals
  • Criminal tax investigations and prosecutions
  • Litigation in federal, state, and local courts
  • International tax compliance
    • Foreign Bank Account Reporting (“FBAR”)
    • Foreign Account Tax Compliance Act (“FATCA”)
    • IRS Voluntary Disclosure for domestic and offshore accounts
  • IRS collections matters
  • Bank Secrecy Act and U.S.A. Patriot Act
  • Corporate and individual income tax, sales and use tax, and transfer tax
  • Compliance with bulk sales laws

What Makes Us Different

  • As tax advisers, our goal is to deliver significant value to our clients in a cost-effective manner.  We communicate frequently and openly with clients to ensure that their business goals and objectives—tax and non-tax—align strategically with our solutions.  
  • We have the ability to call on our corporate, financial services, litigation, and estate planning colleagues for their input, when needed.
  • To keep clients informed of the latest news in the tax controversy field, our attorneys regularly publish a comprehensive review of developments at

Representative Matters

The following sampling of representative matters demonstrates the range of clients we represent and the types of tax issues we handle:

  • Ongoing representation of numerous real estate partnerships in connection with the acquisition and operation of residential properties.
  • Ongoing representation of a real estate developer in connection with the proper accounting method for inventory sales.
  • Ongoing representation of an estate in Tax Court litigation challenging the IRS’s disallowance of charitable contribution and assertion of fraud penalty.
  • Ongoing representation in connection with bank shares tax refund claims.
  • Ongoing representation in connection with litigation involving sales tax refund on electricity.
  • Representation of a former chairman and chief executive officer of a public company in securities, accounting, and tax fraud prosecution and related civil matters in Tax Court.
  • Representation of a clinical laboratory owner in connection with investigation and prosecution for tax and health care fraud, and related civil issues involving IRS collections.
  • Representation of a business owner in federal prosecution for public corruption and related tax offenses.
  • Representation of several individuals in connection with IRS and Justice Department investigations and prosecutions relating to the failure of reporting bank accounts in Switzerland, and subsequent audits by the IRS.
  • Ongoing representation of a foreign bank on compliance issues relating to FATCA.
  • Successfully enrolled numerous individuals in the IRS offshore voluntary disclosure programs relating to undisclosed bank accounts.