Tax Litigation

Tax litigation requires technical expertise, responsiveness and knowledge of complex substantive law.

Duff & Phelps offers trusted opinion and technical prowess to help companies address a variety of issues related to tax compliance disputes. Considering the application of fact and law, Duff & Phelps professionals anticipate, respond to and negotiate issues that may later surface with the Internal Revenue Service or other taxing authorities.

Client Alert: Take-Aways from Gallagher v. Commissioner
In a tax court decision that came out in late June, Judge Halpern addressed the valuation of a closely-held business and addressed over a dozen valuation-related issues in the case. Estate of Gallagher (“Petitioner”) v. Commissioner (“Respondent”) concerned a 15% stake in a private newspaper company. While both Petitioner and Respondent offered competing expert opinions on value, it was the Petitioner’s opinion that received the most criticism. However, the Court’s finding of value was ultimately closer to that offered by the Petitioner’s expert.  A summary table at the end of this article highlights many of the issues and how the Judge ruled on each issue.

Client Alert: Supreme Court Declines Textron Appeal – Tax Accrual Workpapers are Subject to Summons by the IRS
On May 24, 2010 the Supreme Court declined to hear an appeal of the First Circuit Court of Appeals' decision in Textron, which held that a public company's tax accrual workpapers were subject to production under an Internal Revenue Service (IRS) administrative summons (United States v. Textron Inc., 104 AFTR 2d 2009-5208).
Gregory Higgins
Gregory Higgins
 
Managing Director
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