Litigation, including but not limited to:

  • United States Tax Court (pre-assessment and only prepayment forum);
  • Tax Court petition and designation of place of trial;
  • Automatic appeals office review if no appeals pre-petition;
  • Responding to informal and formal discovery;
  • Entering into stipulations;
  • Drafting pre-trial memorandum;
  • Assisting in trial;
  • Analyzing burden of proof, burden of production and burden of persuasion, as well as presumptions thereto;
  • Assisting in the briefing;
  • Reviewing opinions and preparing for appeals;
  • Court of Federal Claims (post-assessment and a refund forum);
  • Establishing prerequisites (Flora) for refund suit;
  • Filing a claim for refund;
  • Arguing mitigation of prepayment rule;
  • Arguing against and working with Department of Justice in Court of Federal Claims; and
  • Making a qualified offer under 7430 for attorney fees and other costs.