Tax Controversy

Recognized by U.S. News & World Report
and Best Lawyers®

Gardere’s tax controversy attorneys have substantial experience handling federal tax controversies at all levels within the IRS and before the U.S. Tax Court, U.S. District Court, and U.S. Court of Federal Claims.

Some of our recent experience includes handling matters involving:

  • Transfer pricing
  • Research tax credits
  • Voluntary disclosures, including offshore voluntary disclosures
  • Penalty abatement and waiver
  • IRS collections
  • Federal excise taxes
  • Captive insurance
  • Charitable conservation easement deductions
  • TEFRA partnership proceedings
  • Mineral depletion
  • Energy tax credits
  • Worthless stock loss
  • Domestic production activities deductions
  • Subpart F
  • Section 6672 trust fund recovery penalties
  • Withholding taxes
  • U.S. trade or business/permanent establishment issues
  • Advance Pricing Agreement/Competent Authority
  • Exempt organizations, including revocation of exempt status
  • Source of income
  • Foreign tax credit
  • U.S.V.I. residency issues
  • Passive foreign investment companies

The Tax Controversy team also routinely handles state and local tax controversies, including numerous cases involving Texas franchise tax, sales and use tax, motor vehicle sales and use tax, and property tax.  We represent clients during Texas tax audits, on administrative appeal, and before the State Office of Administrative Hearings.  We have argued tax cases before the Texas District Courts, Court of Appeals, and the Texas Supreme Court.

Search Tips:

You may use the wildcard symbol (*) as a root expander.  A search for "anti*" will find not only "anti", but also "anti-trust", "antique", etc.

Entering two terms together in a search field will behave as though an "OR" is being used.  For example, entering "Antique Motorcars" as a Client Name search will find results with either word in the Client Name.


AND and OR may be used in a search.  Note: they must be capitalized, e.g., "Project AND Finance." 

The + and - sign operators may be used.  The + sign indicates that the term immediately following is required, while the - sign indicates to omit results that contain that term. E.g., "+real -estate" says results must have "real" but not "estate".

To perform an exact phrase search, surround your search phrase with quotation marks.  For example, "Project Finance".

Searches are not case sensitive.

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