Tax Court Litigation

Tax Court Litigation

  • Attorneys in Freeman’s tax controversy and tax litigation practice have been named to U.S. News and World Report’s Best Lawyers in America list, recognized by Chambers & Partners as among the leading tax litigation attorneys in the United States, and recognized as the “Leading Tax Controversy Litigation Attorney of the Year” for the State of Texas.
  • Our tax litigation attorneys include former IRS trial attorneys, former clerks to the Chief Judge of the United States Tax Court, tax law professors, dual-credentialed CPAs, and attorneys with advanced LL.M. tax degrees from the most prestigious tax programs in the nation. One third of our attorneys serve as tax law professors at tier-one law schools.
  • Freeman’s tax attorneys have extensive trial experience litigating major tax disputes in the United States Tax Court. Our tax controversy attorneys have collectively litigated hundreds of cases before the U.S. Tax Court.

Tax Court Litigation

Our tax litigation practice has a national and international reputation for high-stakes, complex litigation in the United States Tax Court. We are known for providing creative and innovative solutions to the most complex tax problems. Our tax attorneys are experienced litigators with trial-tested litigation skills and in-depth substantive tax knowledge, having collectively litigated hundreds of cases before the U.S. Tax Court.

Best Lawyers® and U.S. News & World Report have recognized Freeman as a “Tier 1” Tax Law firm and our tax attorneys have garnered national recognition for their tax litigation work, such as:

  • The “Leading Tax Controversy Litigation Attorney of the Year” for the State of Texas
  • U.S. News – Best Lawyers® Best Lawyers in America
  • The Best Lawyers in America®, Chambers USA

Consistent with this recognition of our tax litigation practice, Freeman hosts the world’s largest international tax conference, focusing heavily on civil and criminal tax litigation developments in the United States and internationally. We also provide an intensive Tax Court preparation course, training tax attorneys across the nation for the Tax Court’s bar examination and providing tax advocacy and litigation skills.

Notably, our Tax Court in Brief Insight series provides the most comprehensive and consistent blog coverage of U.S. Tax Court decisions among any law firm in the world. We provide an in-depth breakdown of every single written Tax Court opinion on a weekly basis.

Our in-depth knowledge, and status as a recognized leader in the field, is why Freeman is known as the firm that clients seek out when the stakes are high and the issues are complex.

Tax Court Litigation

The Tax Court is a “court of record” pursuant to Article I of the Constitution. It is a specialized court that exclusively hears tax controversies. Unlike other federal courts, a taxpayer is not be required to pay the proposed taxes prior to filing a petition with the Tax Court. The Tax Court is comprised of judges with tax expertise and has jurisdiction to redetermine deficiencies and overpayment in income, gift or estate taxes, and to redetermine transferee liability, make certain types of declaratory judgments, adjust partnership items, order abatement of interest, award administrative and litigation costs, redetermine worker classification, determine relief from joint and several liability on a joint return, review certain collection actions, and review awards to whistleblowers who provide information to the IRS.

Our tax controversy lawyers have extensive experience in Tax Court matters involving partnership audits and litigation under both the TEFRA and BBA regimes, international tax penalties, foreign trusts, valuation, reasonable compensation disputes, unreported income, fraud penalties, other tax penalties, any many other matters.

We Try Cases –  We Win Cases

Freeman is a sophisticated tax trial boutique, hyper focused on advancing our clients’ tax litigation interests. We are committed to delivering world-class counsel in the courtroom using bold, tactical, state-of-the-art approaches to litigation. Our attorneys bring big-firm talent, think-tank intellect, and analytical precision. Our attorneys are not just litigators—they are trial attorneys. We instill and cultivate a difference, creating a focus on the end-game from the beginning.

Knowledgeable Tax Counsel

Freeman’s tax attorneys provide practical counsel and creative solutions, leveraging their combined depth and breadth of substantive tax knowledge. Our tax lawyers provide skillful representation and employ insightful strategies—delivering first-rate caliber services, whether the dispute involves individual, corporate or partnership tax.

High-Stakes Tax Litigation.

We thrive on resolving high-stakes tax disputes and controversies. Our tax controversy attorneys have successfully represented taxpayers in cross-border tax disputes and defending challenges on economic substance and sham transaction grounds, tax fraud penalties, and tax shelter promoter disputes.


The right move at the right time can mean the difference between the right outcome and the wrong one. Strategic victories are no accident. We begin thinking through the end game from day one. And we have tactical trial experience built on strategic approaches that keep the big picture in mind. Tax controversies give rise to unique procedural and substantive considerations that require knowledgeable tax litigation counsel and a depth of tax litigation procedural experience, as well as substantive tax knowledge.

A Depth of Tax Controversy Experience

Our tax cases and experience involve numerous tax litigation issues, including:

  • Conservation easements
  • Micro-captive insurance
  • Foreign Account Tax Compliance Act (FATCA) issues
  • International transfer-pricing
  • International and offshore tax compliance and reporting, including international information returns and penalties
  • FBAR penalties
  • Tax shelter cases, including injunction and penalty cases
  • Valuation issues
  • Tax penalties
  • Digital currency and blockchain

Positioning a tax case for the right resolution, whether through settlement or a verdict, is both an art and a science. Optimal results require skilled advocacy, measured judgment, and a depth of substantive tax knowledge. At Freeman Law, we draw on our experience and wealth of tax knowledge to advise and guide clients through the entire tax controversy process, building the right strategy to resolve tax controversies from day one.

We provide strategic counseling and seasoned advocacy, finding the best path forward in the most complex and trying of situations. In the process, we provide clients with a voice and work collaboratively to position their case in the most favorable light.

And because of our unique substantive and procedural knowledge, we are able to provide a comprehensive approach to the tax dispute resolution process, formulating creative solutions to the most sophisticated tax problems.

Have you got more questions? Please refer to our FAQs for Tax Court.