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. Our nationally recognized lawyers understand the unique procedural nuances of tax cases. Clients have confidence in our years of experience dealing with IRS District Counsel lawyers and judges in Tax Court cases. We have been able to achieve favorable settlements and courtroom victories for our clients when appropriate under the facts and the law. Our lawyers do not hesitate to fiercely fight for fair taxation in court by winning trials. We know how to zealously litigate tax cases with the highest levels of energy, skill, and professional standards. Client tax departments, closely held business owners, and individual clients hire us because of our tract record and our extensive experience.

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 use of 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.