Tax Litigation

BACK TO Tax Controversy and Litigation

Culp Elliott & Carpenter’s Tax Litigation practice represents corporate and individual clients facing complex tax disputes. Our tax lawyers have not only substantive tax expertise, but also advocacy skills needed to powerfully present cases to the IRS and the courts, understanding the unique procedural nuances of tax cases. We have achieved favorable settlements and courtroom victories for our clients when appropriate under the facts and the law.

In civil tax cases, our lawyers:

Vigorously present our clients’ cases at trial in the U.S. Tax Court or other appropriate court
Handle administrative and litigation tax cases against the North Carolina Department of Revenue and other governmental tax agencies in the Southeast

In criminal tax cases, our lawyers:

Represent taxpayers who wish to address prior significant tax reporting issues through the voluntary disclosure process
Protect our client’s rights and work to prevent criminal investigations, indictments and prosecutions in tax-related cases

The range of our tax litigating controversy engagements include:

Residency status disputes in state income tax cases
Innocent spouse tax relief in the context of separation or divorce
Company share valuations in federal estate and gift tax disputes
Conservation easement qualification and valuation disputes with the IRS
Reasonable compensation and travel and entertainment expense defense in closely held business cases
Economic substance issues involving sale/leasebacks, mergers, tax losses and partnership tax controversies
Litigating state tax issues in the N.C. Office of Administrative Hearings