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Cadwalader's tax controversy practice includes the representation of clients both before the Internal Revenue Service and in court. Our lawyers have been involved in all areas of dispute resolution within the Internal Revenue Service with respect to both corporate and individual taxpayers regarding return positions and refund claims, including negotiation and settlement at the audit level, protests and conferences at the appeals level, and requests for technical advice at the National Office level. The Firm's tax attorneys appear before the United States Tax Court and the United States Court of Federal Claims. Cadwalader's current tax docket includes a case in the United States Court of Federal Claims, a petition to be filed in the United States Tax Court, and several controversies at the IRS level involving a diverse range of corporate issues, including some with hundreds of millions of dollars of tax liability at stake.
We have also regularly represented clients in tax controversies involving foreign corporations and individuals operating and investing in the United States, and U.S. corporations operating overseas.