Tax Controversy

Dinsmore’s Tax Controversy team represents business taxpayers including corporations, partnerships, and financial institutions, as well as high-net worth individuals, in complex tax disputes with the Internal Revenue Service, state departments of revenue, and local taxing authorities. Our practice focuses on strategic resolutions and negotiated settlements that provide certainty while minimizing the disruption and cost of extended examinations or unwarranted tax litigation.

A core part of our work is helping clients obtain clarity before an audit or investigation is initiated. We advise on and negotiate pre‑filing agreements, closing agreements, voluntary disclosures, and ruling and determination requests to proactively resolve significant tax matters and reduce future controversy risk.

When disputes arise, our attorneys guide clients through every phase of the administrative process, including audits, administrative appeals, refund and abatement claims, and matters involving assessment, collection, liens, levies, and payment. Our team regularly defends reporting positions and transactions, addresses valuation and accounting issues, and pursues reasonable‑cause abatements and other administrative relief.

Combining deep technical tax knowledge with practical experience and institutional knowledge navigating IRS and state administrative processes, we work to streamline examinations, position matters for early resolution, and achieve durable outcomes for our clients.