Tax Litigation

In addition to serving our clients in a broad range of business transactions, estate planning, and other traditional areas of tax law, Schwabe, Williamson & Wyatt maintains an active and ongoing practice in the area of tax controversies and litigation, including civil and criminal litigation before state and federal courts. The Tax Litigation group includes attorneys who have made numerous appearances before state and federal trial and appellate courts in these areas. We are proud of our accomplishments in this unique and specialized area of tax practice. Our clients include a number of local small businesses, individuals, and exempt organizations, as well as publicly held corporations.

Client Services
Some of our particular areas of tax litigation emphasis and experience include:

• Audit and appeal conferences before IRS and state taxing agencies
• Property tax appeals to Oregon Department of Revenue and Oregon Tax Court
• Tax refund claims and tax refund litigation
• Administrative representation in collection actions by IRS and state taxing agencies
• Appellate representation on tax issues before federal and state appellate courts
• Collection due process appeals
• Employment tax examinations
• Worker classification (employee/independent contractor)
• Trust fund recovery penalty
• Jeopardy and termination assessments
• Voluntary disclosures
• Defense of federal criminal tax cases
• Defense of federal white-collar criminal cases
• Defense of civil and criminal forfeiture actions
• Third-party litigation in areas of wrongful levies, transferee liabilities, nominee liens and levies
• Consultation with accountants on issues of dealing with internal revenue service criminal investigation division and other federal and state law enforcement agencies