Comprised by a diverse team of tax and litigation attorneys, Hunton’s tax controversy practice seeks to resolve the most challenging tax issues. We represent clients at all stages, from IRS audits and appeals to tax litigation, as well as before state tax authorities and tribunals or courts with jurisdiction over state tax disputes. Our approach involves collaborating with leading experts and working closely with federal, state, and local agencies to develop the facts necessary for effective case presentation. We have established distinctive and assertive strategies to address contentious tax matters and are frequently called upon at the last minute to tackle issues that other law firms and accounting firms have been unable to resolve.

We represent clients in the following areas:

• IRS audits and administrative appeals. We have extensive experience representing clients in industry and emerging issues before the IRS audit and Appeals Office functions.
• Issue resolution. We obtain private letter rulings (PLRs), technical advice memoranda (TAMs), and pre-filing agreements (PFAs), as well as seek relief through other avenues at all levels of the IRS.
• Government relations. We regularly interact with Congressional tax-writing committees and staff and high levels of the US Treasury Department and IRS Office of Chief Counsel, as well as other Executive agencies, regarding critical legislation, major policy changes, regulations, and published guidance.
• Energy tax controversy. Our team has particular experience representing major energy companies, manufacturers, utilities, and financial institutions advising with respect to disputes and litigation involving clean energy tax credits.
• Federal tax litigation. We represent clients in the US Tax Court, the Court of Federal Claims, and various District Courts, as well as in appellate matters in the US Circuit Courts of Appeals and US Supreme Court.

Our approach—early attention to tax controversies—not only affords the benefit of strategic consulting to protect evidentiary privileges, develop a strong record, and build a foundation for a favorable outcome, but also saves time and money in the long term and protects clients from taking detrimental positions in the early stages of an IRS audit or appeal. We know that every audit and tax issue has the potential to turn into a serious and prolonged audit, administrative appeal, and possibly even litigation, and that IRS auditors come prepared. Taxpayers, likewise, should engage experienced tax controversy lawyers and devise a formal strategy as soon as possible in the life of a tax controversy. We are here to help.