Tax Controversies“Tax controversy” naturally calls to mind litigation, an area in which Ivins, Phillips & Barker has long excelled. Our attorneys, however, never lose sight of the fact that controversies in the field of federal tax start during the audit process and proceed through the appeals process long before arriving in court. In the best interests of our clients, we have always vigorously represented them before the various branches of the Internal Revenue Service with a view to achieving favorable settlements. In the vast majority of cases, we obtain settlements that benefit our clients. When advantageous settlements cannot be negotiated, our skilled and experienced trial and appellate lawyers can provide our clients with the same vigorous representation before the courts. 
Our litigation practice dates back to 1935, when the firm was founded by two original members of the Board of Tax Appeals, James S.Y. Ivins, and Percy W. Phillips. The first tax opinion issued by the Board, found at 1 B.T.A. 1, was authored by Judge Ivins. Throughout the decades since 1935, litigation before all of the trial courts having original jurisdiction of federal tax cases, and before the United States Courts of Appeals and the United States Supreme Court, has been a staple of our practice. The firm has had the rare experience of having tried four tax cases before the United States Supreme Court, most recently in United Dominion Industries v. United States , an 8 to 1 decision in favor of the taxpayer in 2001. We have the resources to handle all varieties of tax cases, including cases involving the most complex legal and factual issues. In recent years, our litigation clients have included, among many others, Xerox, Eastman Kodak, Bayer, Dominion Resources, Progress Energy, Dana, CSX, Hughes Aircraft, BTR, Saudi Aramco, Borg Warner, Vulcan Industries, Merck, Fidelity Investment, and Morgan Creek Productions. Additionally, we have become active in alternative dispute resolution, from the representation of clients considering mediation or arbitration in cases before the Internal Revenue Service Appeals office, to representations seeking advance pricing agreements, competent authority agreements, East trade settlements, and pre-filing agreements. Our tax controversy attorneys likewise act in a judicial capacity in disputes between parties that are not clients of the firm and have been used in many federal tax cases as expert witnesses. Our California office has enjoyed considerable success in representing clients before the California Franchise Tax Board and State Board of Equalization. We also have represented clients in tax proceedings in a number of other states. Prospective clients should bear in mind that, unlike many of our competitors, we make every effort to staff all matters in controversy, whether before the Internal Revenue Service, a state tax authority or a court, in the most economical matter possible. We do not overstaff cases, and our clients invariably compliment us for our ability to keep their litigation costs within reasonable bounds. See more information on attorneys in this practice group H. Stewart Dunn, Jr. We have offices in Washington, D.C. and Los Angeles, California and provide legal advice and services to clients both nationally and internationally.
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