Tax Litigation

Tax controversies require a blend of technical expertise and litigation experience to effectively navigate and resolve tax controversies with the Internal Revenue Service and U.S. Department of Justice. Brownstein’s Tax Litigation Group possesses the relevant experience to resolve disputes effectively and efficiently. Brownstein’s tax lawyers have the necessary technical expertise to handle complex tax issues, significant experience litigating matters in federal district courts and the U.S. Tax Court, and experience with criminal tax prosecutions.

Our tax dispute attorneys advise clients on a wide range of issues, including responding to information requests, disputing audit adjustments with the IRS, and litigating matters against the IRS and DOJ in situations where a satisfactory resolution cannot be reached short of litigation and trial. We understand the disruptive nature of an IRS audit and any resulting tax dispute, and work with our clients to resolve issues quickly, efficiently and with the best possible outcome for our clients.           

Representative Matters
  • Successfully represented large mine in multi-million dollar tax dispute with county.

  • Represented real estate development firm to obtain a partial IRS concession of a significant charitable contribution deduction disallowance.

  • Represented individual client in obtaining partial concession by the IRS of “hobby loss” case, in which IRS proposed to completely disallow claimed losses relating to a horse development, training and showing business.

  • Represented real estate development firm in obtaining a full IRS concession of IRS agent’s determinations that (1) client was a dealer in real property and that gain on client’s land and option sales should be subject to ordinary income treatment as sales of inventory (rather than capital gain on sales of investment assets, as reported), (2) client should not be permitted to offset gain on sales of property with client’s basis in its sold assets, and (3) a sale transaction was tax-motivated, and therefore income from the transaction should be reallocated between two client-affiliated entities without identity of ownership.

Meet The Team

Andrew C. Elliott Shareholder T 303.223.1154
J. Tenley Oldak Shareholder T 303.223.1159