Strategies for Tax Litigation is an authoritative, insider's perspective on best practices for defending clients in tax litigation cases. Featuring partners from some of the nation's leading law firms, these experts guide the reader through the preparation and process involved in handling tax disputes. From understanding the role of the IRS to being aware of new regulations and procedures, these authors reveal strategies for keeping up with a rapidly evolving tax law environment. Additionally, these top lawyers offer advice on constructing a successful defense strategy, managing client expectations, collecting and preparing evidence, and keeping up with strict deadlines in the Tax Code. Finally, these leaders discuss the importance of avoiding common mistakes, conducting thorough internal investigations, and learning from previous high-profile cases. The different niches represented and the breadth of perspectives presented enable readers to get inside some of the great legal minds of today, as these experienced lawyers offer up their thoughts around the keys to navigating a widely-relevant area of law.
Inside the Minds provides readers with proven business and legal intelligence from leading C-Level executives and lawyers. Each chapter offers thought leadership and expert analysis on an industry, profession, or topic, providing a future-oriented perspective and proven strategies for success. Each author has been selected based on their experience and C-Level standing within the business and legal communities.
1. Jess A. Bahs, Shareholder, Howard & Howard Attorneys PLLC - "Dealing With Tax Litigation Situations"
2. Michael F. Patton, Partner, DLA Piper LLP - "Transfer Pricing and Other Key Issues in Today's Tax Litigation Cases"
3. Gabriel G. Tsui, Partner, Handler Thayer LLP - "Navigating the Waters of the Increasingly Aggressive IRS"
4. William F. Colgin Jr., Partner, Morgan Lewis & Bockius LLP - "The US Tax Court Changes its Discovery Rules"
Appendix A: Treasury Regulation ? 1.6664-4
Appendix B: Internal Revenue Code ? 6662
Appendix C: Internal Revenue Code ? 6707A
Appendix D: United States v. J. Bryan Williams
Appendix E: Canal Corporation v. Commissioner
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Table of Contents
Dealing with Tax Litigation Situations Jess A. Bahs 7
Transfer Pricing and Other Key Issues in Today's Tax Litigation Cases Michael F. Patton 21
Navigating the Waters of the Increasingly Aggressive IRS Gabriel G. Tsui 53
The Us Tax Court Changes its Discovery Rules William F. Colgin 71