Taxation: Our Taxation Group brings a broad range of experience in tax law to our clients.  We represent clients in federal, state and local income, franchise, sales, property tax planning and compliance and dispute resolution.  We also represent clients with issues involving multi-state taxation, nexus and related matters.  Our tax planning involves estate planning that is in conjunction with asset protection.  Moreover, our tax team has experience defending taxpayers in criminal tax matters.  Our lawyers are trained accountants that work closely with other lawyers in our corporate transactions and business law areas to develop and implement optimal tax planning strategies for complex corporate transactions such as acquisitions, mergers, divestitures and other reorganizations. Furthermore, we have in-depth experience in the taxation of individuals, S corporations, limited liability companies, partnerships and similar "pass-through" entities.  The experience of this group includes the full range of services for individuals, small and mid-sized companies including executive compensation and compensation arrangements such as stock appreciation and phantom stock plans, stock option programs for corporate employees and tax deferred exchanges of real estate.  We also provide tax services to tax-exempt entities of varying sizes including both public charities and private foundations on a broad range of income tax matters and in securing and maintaining tax-exempt status. Representative Services Aggressive, Creative, And Comprehensive IRS Audit Representation To Prevent IRS Abuse, Error, Bluff And Intimidation. Identification Of Argument Favorable To Taxpayer And Development Of Factual And Legal Issues To Reduce Tax Liability. Comprehensive Tax Law Research, Technical And Interpretative Analysis. Drafting Of Technical Memoranda, Rationale, And Supporting Authority, Including Protests For Appeals. Audit Strategy And Defense. Procedural Remedies Including Appeals And Conferences Negotiations At All Levels. Closing Agreements Under Section 7121 Of The Code To Protect Taxpayers From Inconsistent Treatment Or Bind the IRS To A Negotiated Settlement. Tax Penalty And Interest Defense, Reduction, Abatement Or Elimination. Collection, Levy, Seizure and Lien Protection and Defense. Problem Resolution Office and Taxpayer Advocate Utilization. Review Of The Mode Or Time For The Collection Of Any Tax, Notice And Demand For Taxes, Collection Liability, Release Of Lien, Discharge Or Seizure Of Property, Levy And Distraint, Surrender Of Property Subject To Levy, And Redemption Of Property. Fraud Defenses. Offers in Compromise To Reduce Final Tax Determinations And Penalties Where Doubt Exists As To Whether The Taxpayer Owes The Liability Or When There Is Doubt That The Liability Can Be Collected In Full. Requests For Technical Advice and Determination Letters To Clarify The Interpretation And Proper Application Of The Tax Law, Treaties, Regulations, Revenue Rulings Or Other Published Precedents. Requests For Private Letter Rulings From The IRS Associate Chief Counsel For Pre-Transaction Tax Determinations To Interpret And Apply The Tax Laws To A Specific Set Of Facts. Planning For A Tax-Free Merger, Spin-Off Or Other Corporate Reorganization. Requests For Accounting Method And Period Changes From IRS National Office. Negotiated Settlements. Preparation Of Installment Agreements For Tax Payments. Informal Consultation Or Advice Court Appeals & Brief Preparation - U.S. Tax Court, The US. Court Of Federal Claims, Or The U.S. District Court.