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Tax Controversy

The principal goal of the Hodgson Russ attorneys working in the area of tax dispute resolution is to win your case. Our tax 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.

We strive to find innovative solutions to seemingly impossible situations. Focusing on developing a sound strategy, we seek to resolve tax disputes successfully without litigation. But when litigation is required, our record is exemplary. 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. We often work closely with other advisors, such as in-house counsel or financial advisors. 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 tax attorneys can work one-on-one with the client or become a valuable addition to a team of professionals.

Our 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 advocate for our clients from virtually every angle, as tax disputes are rarely just about tax law.

Hodgson Russ tax attorneys are frequently asked to give presentations for prestigious legal and business organizations. We are very active in the American Bar Association, key positions on the executive committees of the New York State Bar Association and various tax committees, and teach tax courses at major law schools.

Our tax dispute resolution attorneys are on the forefront of the law, writing the books other practitioners read. These publications were written by our attorneys:

  • Contesting New York State Tax Assessments, 4th Edition, New York State Bar Association
  • 2019 Guidebook to New York Taxes (CCH)
  • New York Residency and Allocation Audit Handbook (CCH)
  • New York State Sales and Use Tax Answer Book (CCH)
  • What to Expect in a Sales and Use Tax Audit (Hodgson Russ)
  • What to Expect in a Residency Audit (Hodgson Russ)

For information about how to obtain any of these handbooks, please click here.

Other publications written or edited by our tax attorneys include:

  • "Broadening New York's Decanting Statute” (New York Law Journal)
  • Canadian Tax Highlights (a monthly publication from the Canadian Tax Foundation)
  • Annual Guidebook to New York Taxes (CCH)
  • A monthly column in State Tax Notes (a national publication about state and local tax)
  • New York Residency & Allocation Audit Handbook (CCH)
  • Canadian Companion to 1040 Preparation and Planning Guide (CCH)
  • Practice Advisor (LexisNexis)

In addition, Paul R. Comeau and Tim Noonan, received the Burton Award for Excellence in Legal Writing for an article they wrote about executive compensation and employer withholding.

Hodgson Russ LLP has been awarded prestigious "Best Law Firms" rankings by Best Lawyers/U.S. News & World Report in the categories of National Tier 2, Tax Law and Litigation – Tax, Metropolitan Tier 1, Tax Law, and Metropolitan Tier 2, Litigation – Tax.


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