Understanding a Complex System
As federal tax codes become increasingly complex, businesses and individuals must be that much more diligent in ensuring their compliance. The attorneys in Murphy Pearson’s Tax Practice represent clients before the Internal Revenue Service (IRS), California Franchise Tax Board, Employment Development Department (EDD), and State Board of Equalization in matters involving tax controversies and avoidance. Our experience includes representing clients in:
- Tax controversy, offers in compromise
- Tax mitigation, private letter ruling requests
- Tax dispute consultation
- Tax litigation
- International penalty mitigation and disclosures
- General counsel and risk management consulting for tax preparers
- Defense of tax crimes
Our Professional Liability attorneys also represent CPAs, accountants, bookkeepers and other fiduciaries in tax-oriented malpractice litigation.
Bringing Confidence to the Process
Because the process can often seem intimidating, our tax group ensures our clients are well informed and confident about their taxpayer rights. Detailed preparation helps us produce positive results and enables us to offer a speedy assessment of the situation and practical advice regarding available options. Over the years, we have found that negotiations with the tax authorities can frequently yield results that are faster and more desirable than administrative or judicial litigation.
Our approach emphasizes timely analysis of tax issues and modeling of various options to provide our clients with critical information to ease decision-making and make choices clearer. This same process can be used for planning purposes before controversies occur. For example, we may seek IRS sanction proactively to treat transactions in a certain way by means of a Private Letter Ruling to support a planned tax strategy.
Integrated Planning
Our tax attorneys work closely with our business lawyers to structure and execute complex transactions from a tax perspective, so that our clients are well positioned to achieve their business objectives. Decisions related to real estate and other transactions also may benefit from the involvement of our tax team. We provide services in all aspects of business and individual tax planning, including comprehensive estate planning to preserve family wealth and minimize tax exposure.
Tax Controversies
We represent public and private business entities (corporations, partnerships and limited liability companies), private clients and tax-exempt organizations in resolving federal, state and local tax controversy matters. We have in-depth experience in client representation before U.S. Tax and Federal Appellate Courts and State Trial and Appellate Courts; at state and local tax examinations and administrative proceedings; at federal tax examinations and IRS appeals offices; and in administrative and grand jury criminal tax investigations.
