Tax Controversies

Practice Contacts

Emily A. Parker
Senior Counsel
Mary A. McNulty
  • |
  • |
  • |
View Tax Controversies

Thompson & Knight tax litigation attorneys are effective tax dispute advocates for public and private corporations and partnerships, foundations and tax-exempt entities, and individuals. We regularly handle Internal Revenue Service audits, protest letters and position papers contesting tax adjustments and penalties, administrative proceedings, assessment appeals, federal and state tax refund and deficiency litigation, disputes concerning foreign companies and their U.S. affiliates and employees, and estate and gift tax disputes that include the valuation of closely held and family businesses. When tax disputes become lawsuits, we represent clients in the United States Tax Court, the U.S. Court of Federal Claims, and federal district courts, appealing cases to the U.S. Courts of Appeals and the U.S. Supreme Court.

In addition to our civil tax practice, we represent clients faced with criminal investigations and prosecutions on tax offenses as well as related white collar criminal charges. Attorneys in our group are licensed to practice in a number of states, and they collaborate with our local counsel network to resolve tax disputes virtually anywhere in the U.S. and around the world.

As part of our firm's preeminent energy industry practice, we have a long history of successful tax litigation counsel for petroleum, hard minerals, and natural resources clients. For example, we represented Texaco in the largest tax case ever tried before the United States Tax Court, an international transfer pricing controversy involving several billion dollars in alleged deficiencies.

Our attorneys have been recognized and honored among their peers for their abilities and dedication. We are proud that Thompson & Knight received a national first-tier ranking for Tax Litigation in the 2018 edition of "Best Law Firms," the preeminent listing of the nation's top legal practices from U.S. News - Best Lawyers®. The Firm is also ranked among the top firms in the nation for U.S. Taxes: Contentious in the 2017 edition of The Legal 500 US. According to clients quoted in the directory, the team “handles a broad range of tax controversy matters, from IRS audits and position papers contesting tax adjustments and penalties, to administrative proceedings and assessment appeals, to federal and state tax refund and deficiency litigation.”

Our backgrounds include invaluable experience with the United States Attorney's Office, the Department of Justice Tax Division, and as the Acting Chief Counsel and Deputy Chief Counsel for the Internal Revenue Service. We also have decades of experience litigating precedent-setting cases that involve complex and novel tax issues, and many of our cases have gained national attention because they have a major economic impact and develop previously unsettled issues of tax law.