FRS’s tax practice has handled virtually every type of state and federal tax controversy before state and federal administrative agencies and courts. Our matters include numerous cases in state trial and appellate courts and federal district and appellate courts, the Court of Federal Claims, and the United States Tax Court. We help our clients avoid tax litigation but are prepared to successfully represent them when forced to try a tax case.
Our tax controversy team handles cases for corporate, individual, trust, and partnership taxpayers. These cases involve issues arising across all industries and financial or investment activities. Our tax controversy representation has involved issues related to tax accounting, inventory, R&D, valuation, reasonable compensation, deductibility of captive insurance premiums, and debt versus equity determinations, among others.
We have represented clients and argued cases in numerous major state tax matters related to issues including sales and use tax, intangible personal property taxes, and corporate income tax. We have argued cases at the administrative hearing level through the highest state courts.