Tax Controversies

Schiff Hardin attorneys represent individuals and fiduciaries in disputes with the Internal Revenue Service (IRS) concerning federal estate, gift and generation-skipping tax, individual fiduciary and income tax, and taxation of family business entities. We include among our attorneys former IRS and Department of Justice personnel who can assist at all stages of tax controversies from initial audit through contested court proceedings, if necessary. We have an excellent track record of resolving tax controversies privately and favorably to taxpayers.

We have dealt with a broad range of tax issues, including:

• Valuation of closely-held operating businesses
• Valuation of interests in investment limited partnerships and LLCs, including valuation discounts
• Valuation of works of art and other unique personal property items
• Validity of two-life grantor retained annuity trusts (participating in the only case resulting in a taxpayer victory with this technique)
• Validity of preferred interest freezes in closely-held entities
• Exclusion of assets from taxable estate, including insurance, trusts, and controlled family businesses