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Tax Dispute Resolution

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Practice Group Leader

Alice A. Joseffer

Attorneys

James M. Bandoblu Jr.

Brad A. Birmingham

Alvan L. Bobrow

Paul R. Comeau

Kevin K. Gluc

Mark S. Klein

Robert J. Lane Jr.

James P. Milbrand

Timothy P. Noonan

Marla Waiss

No. 1 Goal: Winning Your Case

The principal goal of the Hodgson Russ Tax Dispute Resolution Practice Group is to win your case. Our attorneys represent clients in tax disputes from the audit level through the appellate process and in the court system. We work at the local, state, federal, and international levels, and in all types of tax disputes— business tax, personal income tax, sales and use tax, estate and gift tax, international tax, and controversies under international treaties.

Creativity is our hallmark, and we strive to find innovative solutions to seemingly impossible situations. Focusing on developing a sound strategy, we seek to resolve tax disputes quickly and efficiently without litigation. However, in some instances where the law or interpretive authority has run counter to our clients’ interests, we have sought—and in many instances obtained—policy, regulatory, or statutory changes. And when litigation is required, our record is exemplary. We often work closely with other advisors, such as in-house counsel or financial advisors, and we can handle as much or as little of a matter as appropriate. Whether the client is an individual or a Fortune 500 company, our attorneys can work oneon- one with the client or become a valuable addition to a team of tax professionals.

Knowledge Is an Edge

Hodgson Russ tax attorneys provide creative solutions for the full spectrum of clients’ business and personal transactions and objectives, from international mergers and acquisitions to wealth preservation. Our more than 50 tax attorneys have collective experience in virtually every facet of tax law. We also have attorneys who practice in a full range of other business areas, including corporate and securities, intellectual property and technology, labor and employment, and employee benefits. Our multifaceted approach affords us the opportunity to defend our clients from virtually every angle, as tax disputes are rarely just about tax law.

The attorneys in the Tax Dispute Resolution Practice Group are on the forefront of the law, writing the books other practitioners read. Recent publications written in whole or in part by our attorneys include:

• ”Overview of the U.S. Transfer Tax System” (Vol. 26, Estates, Trusts & Pensions Journal)
• Canadian Tax Highlights (a monthly publication from the Canadian Tax Foundation)
• CCH’s Annual Guidebook to New York Taxes
• A monthly column in State Tax Notes (a national publication about state and local tax)
• The New York Residency & Allocation Audit Handbook (4th ed., CCH)
• Canadian Companion to 1040 Preparation and Planning Guide (7th ed., CCH)
• LexisNexis Tax Practice Insights: New York
• In addition, two Hodgson Russ attorneys received the Burton Award for Excellence in Legal Writing

Experience Matters

Attorneys in the Tax Dispute Resolution Practice Group have successfully resolved challenging tax controversies, including:

• Negotiating a favorable settlement for an international promotional products supplier in a transfer pricing dispute regarding tax deductibility of patent royalties and intellectual property ownership
  

• Obtaining a full concession in the Tax Court by the IRS regarding estate tax issues
  

• Obtaining a victory in New York’s highest court in a decision that struck down New York’s gas import tax on constitutional grounds and cancelled a multi-million dollar tax assessment

• Becoming one of the only law firms to successfully impose the estoppel doctrine on the Tax Department in a matter litigated in the New York State Division of Tax Appeals

• Compiling an incredible record of success in litigated matters in New York’s Division of Tax Appeals, achieving victories in multiple cases over the past seven years, thereby saving clients tens of millions of dollars in the process

Respected Professionals

Hodgson Russ attorneys are frequently asked to give presentations for prestigious legal and business organizations. We are very active in the American Bar Association and hold key positions on the executive committees of the New York State Bar Association and various tax committees. One of our partners is chair of the Committee on State and Local Taxation of the Association of the Bar of the City of New York. Additionally, our attorneys teach tax courses at major law schools. Hodgson Russ presents numerous tax-related seminars and other educational offerings to our clients and their advisors.

Practice restricted to U.S. law.