Tax Controversy/Litigation

Adkisson Pitet LLP represents clients in tax audits and disputes before the IRS, Franchise Tax Board of California, and the State Board of Equalization.  We have effectively resolved cases for individuals and businesses who were facing assessments from $100,000 to over $2 million. Our cases typically involve complex matters such as:

Tax Controversy:

  • Partnership taxation


  • Individual income tax audits and appeals before the IRS and FTB
  • Entity income tax audits and appeals before the IRS and FTB
  • Sales and use tax audits and appeals
  • Payroll tax audits and appeals
  • Report of Foreign Bank and Financial Accounts (FBAR)
  • Foreign Account Tax Compliance Act (FATCA) and international tax issues
  • Foreign Investment in Real Property Tax Act (FIRPTA) compliance matters
  • Foreign tax credits
  • Property tax appeals with the SBE
  • County property tax controversies
  • Audits of estate and gift tax returns
  • Captive insurance cases
  • Collection due process disputes
  • Penalty and interest issues
  • Tax shelter remediation
  • Tax-exempt disputes
  • Valuation issues

If you would like further information on our Tax Controversy/Litigation practice, please contact Joe Petrucelli.