Tax Litigation & appeals
Tax Litigation & Appeals go hand in hand with estate and business planning and estate administration. Whether it involves the removal of tax liens, negotiating tax settlements, or engaging in disputes with taxing officials, the law firm is prepared to bring matters to resolution. Our lawyers have been successful in resolving complex tax issues as well as valuation disputes and tax liens at the local, state and federal level.
Our recent cases have involved a $20 million tax dispute for trustees in the United Kingdom with taxing authorities in Rhode Island; resolving a $2 million federal estate tax liability and sale of business assets to satisfy the deficiency and related agreement with the IRS; resolving a tax deficiency imposed in error by the IRS because the client’s accountant erred on tax returns for a charitable remainder trust; negotiating a resolution of a $500,000 sales tax deficiency for a nationally known restaurant with the Commonwealth of Massachusetts Department of Revenue; settling a tax dispute with the IRS related to the dissolution of a business partnership for the remaining partner and entering into a settlement with the discharged partner who was in default on various financial obligations to the other partner; appealing a pro bono case to the Rhode Island Superior Court for the refusal of the Rhode Island Division of Taxation to enter into a tax payment plan for a veteran of the Iraq War whose military service interrupted mortgage and tax payments; engaging in litigation and a subsequent settlement over valuation and tax disputes in the dissolution of a corporate structure of a medical group for the departing shareholder; obtaining a settlement on the allocation of estate taxes over assets distributed by multiple means at death because the person with power of attorney undid an estate plan causing a major dispute over distributions as well as the allocation of estate taxes, particularly over tax deferred investments and retirement accounts; completing estate tax returns for multiple estates with potential federal estate tax liability; amending multiple years of income tax returns because various deductions and exemptions were not properly made, resulting in substantial refunds for the clients; and receiving waivers of state withholding tax on the sale of real estate by an out of state trustee for property in Rhode Island.