Tax Dispute Resolution

Tax Dispute Resolution - What Makes Us Different?

We Know How to Resolve Tax Disputes Favorably

  • We Understand Tax Dispute Resolution Procedures.  We understand dispute resolution procedures –including the overly complex, old fashioned and highly idiosyncratic procedures governing Massachusetts tax litigation. Our understanding of these arcane tax procedures is often critical to the successful resolution of your tax dispute.
     
  • We Are Prepared To Take Your Case Through Audit, Trial and Appeal. Your case is only as good as the facts we can prove at trial.  From the very beginning, we focus on both the law and the facts. Our ability to try your case helps us to achieve favorable settlements.
     
  • We Also Understand the Business Context of Your Tax Controversy. We also understand the effect of tax litigation on your competitive position and on your balance sheet and bottom line.

We Are Highly Experienced

Our focused litigation teams typically include a partner, associate and paralegal with more than 40 years of combined tax dispute-resolution experience. Each of our attorneys has a Master of Laws degree in Taxation (LL.M.).

We Are Cost Effective

  • The Three-To-One Rule.  We try to achieve tax reductions equal to at least three times our anticipated legal fees.  We call this the “Three-To-One Rule.”  Although we can never guarantee success, we consistently achieve favorable results by evaluating your case carefully when you first meet with us.  We then reevaluate your case regularly as new information becomes available.  Whenever we feel that we cannot meet our Three-To-One Rule, we immediately bring this issue to your attention.
  • What Are the “Opportunity Costs” of Your Tax Dispute?  We have learned that the total cost of resolving a tax dispute is often much greater than the dollar cost of an eventual tax settlement.  The total cost also includes your opportunity cost – the time and effort you could have spent more profitably on other matters.  Opportunity costs are most significant for those who own and manage their own businesses. We are skilled at minimizing your “opportunity costs.” 
     
  • What is the “Precedent Cost” of Your Tax Dispute?  The cost of your tax dispute is often far greater than the cost to resolve an audit for a single tax year.  Sometimes the same tax issue will surface year after year until finally resolved.  Therefore, it may be more cost effective to resolve a tax dispute once and for all – even though our professional fees may exceed the normal “Three-To-One Rule” for this scenario. 
     
  • We Try to Minimize the “Total Costs” of Resolving Your Tax Dispute. We work with you and with your legal and accounting advisors to identify all the costs of your tax dispute.  Only then can we devise a strategy that balances and minimizes all of these costs.  These costs include:
    • Your “Opportunity Cost”
    • Your “Precedent Cost”
    • Your Accountant’s Fees
    • Taxes, Interest and Penalties Paid to the Government
    • Our Fees
  • Cost-Benefit Analysis.  We always weigh the cost of litigation against the likelihood and degree of success.  We alert our clients when our continued representation no longer seems cost-effective. 
  •  Reasonable Blended Rates.  Our focused litigation teams contain professionals with different levels of skill, experience and billing rate so that our blended billing rates are reasonable.
  • Working With Client Advisors.  We cooperate fully with your legal and financial advisors, including your lawyers and accountants.


We Are the Right Size for You

We are big enough and sophisticated enough to get the job done and small enough to get to know you well.

We Are Respected for Our Professionalism

We are respected for our professionalism by the Internal Revenue Service and the Massachusetts Department of Revenue.