Practice Chair(s)
Whether we are engaged at the beginning of a controversy, or called in after other attempts at relief have failed, we know how to explore every approach to achieving the best resolution for the client.
Overview
Chamberlain Hrdlicka’s nationally recognized Tax Controversy & Litigation Practice is composed of attorneys experienced in advising and representing taxpayers before federal, state and local taxing authorities and in all federal and state courts in which tax disputes are litigated. Our team includes attorneys who have litigated cases for the United States Department of Justice Tax Division and IRS Office of Chief Counsel, served as IRS Appeals Officers and Revenue Agents, and clerked for the United States Tax Court. Our team also includes attorneys who have CPAs, MBAs, or Masters in Laws in Taxation, or have served in important tax positions in private industry.
What separates a true tax controversy firm from those who profess to handle “tax controversies” is the combination of many critical elements, including:
- Substantive tax expertise on a wide array of sophisticated tax issues,
- Comprehensive understanding of the nuances of tax procedure and the tax controversy process,
- Extensive knowledge about, and experience dealing with, the IRS, the Department of Justice and state taxing authorities, and
- A proven track record of successfully litigating unresolved tax claims.
Our clients range from the largest multinational corporations to every other conceivable form of business entity, estates, trusts, individuals and nonprofit organizations. Our client engagements cover the full spectrum of substantive tax issues involving income, estate and gift, employment, excise taxes and tax-exempt entities. They arise in all phases of the tax controversy process, from the beginning of the tax audit, to the preparation of tax protests and negotiation with IRS Appeals, to litigation in the United States Tax Court, the Federal District Courts, and the Court of Federal Claims. We also have extensive experience arguing appeals in the United States Courts of Appeals, and the United States Supreme Court. Similarly, at the state level, we represent taxpayers in all phases of the controversy and litigation process.
In criminal tax matters, we represent companies and individuals who are alleged to owe tax or be liable criminally for failure to comply with the tax laws. Representative engagements include defending taxpayers against allegations of failure to report income, fraudulent overstatement of deductions, preparation of false tax returns, failure to collect and pay over employment taxes, and conspiracy to obstruct the collection of taxes.
Whether we are engaged at the beginning of a controversy, or called in after other attempts at relief have failed, we know how to explore every approach to achieving the best resolution for the client.
Areas of Expertise
- Pre-controversy tax advice
- Tax audits
- Administrative appeals
- Alternative Dispute Resolution
- Freedom of Information Act requests and actions
- Summons enforcement actions
- Representation of taxpayers under criminal investigation
- Civil and criminal tax litigation in United States Tax Court, Federal District Courts, Court of Federal Claims, and state courts.
- Appellate advocacy in the United States Court of Appeals, United States Supreme Court, and state courts.
News
News
- January 12, 2018
- November 16, 2017
- Stewart M. Weintraub Named 2017 AV Top-Rated Lawyer in Real Estate Law by Martindale-Hubbell and ALMChamberlain Hrdlicka state and local tax (SALT) practice chair recognized in special section in American Lawyer, Corporate Counsel and National Law Journal
- National law firm achieves top rankings in tax law, tax litigation and trust and estates law
- Litigation and Controversy Tax, Employee Benefits (ERISA), Government Relations Lawyers from Chamberlain Hrdlicka Listed Among Best in U.S.
- Stewart M. Weintraub, Kenneth I. Trujillo, Matthew S. Olesh, Jennifer Weidler Karpchuk recognized among top lawyers in Pennsylvania
- Attorney in the Philadelphia office focuses her practice on State and Local Taxation (SALT)
- Philip Karter is the only Pennsylvania tax controversy attorney ranked nationally in his field by Chambers & Partners in the 2017 Chambers USA guide
- Chamberlain Hrdlicka senior counsel discusses attorney-client privilege at annual anti-fraud conference
- Chamberlain Hrdlicka lawyer discussed preparing witnessesMay 22, 2017
- Stewart M. Weintraub, Kenneth I. Trujillo, Jennifer Weidler Karpchuk recognized among top lawyers in Pennsylvania
- Kevin F. Sweeney discusses attorney-client privilege with anti-fraud organization ACFE
- Chamberlain Hrdlicka state and local tax (SALT) practice chair was the overall chair of the annual ABA/IPT Advanced Tax Seminars
- Former federal tax prosecutor brings deep knowledge of high-stakes IRS audits, tax litigation, white-collar criminal defense, and banking matters
- Philip Karter and Herbert Odell are the only Pennsylvania tax controversy attorneys ranked nationally in their field by Chambers & Partners in the 2016 Chambers USA guide
- Chamberlain Hrdlicka lawyer Stewart M. Weintraub presented programs on state tax issues at American Bar Association Tax Section’s Fall 2015 Meeting
- Chamberlain Hrdlicka again recognized nationally in The Legal 500 and Chambers & PartnersJune 2015
- Bucks County Courier Times, April 17, 2015
- Tax attorneys from Philadelphia law firm update valuable PA tax law resource
- Bloomberg BNA Tax Management Weekly State Tax Report, December 2014
- U.S. News & World Report recognizes Chamberlain Hrdlicka attorneys in practice areas of construction law, employee benefits, immigration law, tax litigation and controversy, and trusts and estates.
- Revenue at mid-size firms lags nationwide, but Chamberlain Hrdlicka’s figures are outpacing 2013
- Tax attorney Larry A. Campagna tops roster of eight Chamberlain Hrdlicka attorneys ranked by Chambers & Partners in its annual guide to country’s top lawyers and firms
- Bloomberg BNA State Tax Blog, February 5, 2014
- Lawyers from the Philadelphia office of Chamberlain Hrdlicka presented at a seminar discussing strategies for attorneys and accountants who advise business ownersJanuary 2014
- Named among Nation's Top Ten Tax Controversy Firms by The Legal 500June 26, 2013
- June 2010
- TaxBlawg.net, June 8, 2010
- June 2010
- TaxBlawg.net, May 18, 2010
- Philadelphia Business JournalMarch 15, 2010
- June 2009
- June 2009
- June 2009
- April 2009
- Chamberlain Hrdlicka Tax Controversy Alert, January 2009
- June 2008
- June 2008
- June 2007
- Tricky Issue Spurs Tax Court Ruling And IRS WarningMay 9, 2007
- Atlanta Business Chronicle, August 11, 2006
- July 11, 2006
Presentations
Seminars & Presentations
- Chamberlain Hrdlicka senior counsel will discuss attorney-client privilege at annual anti-fraud conferenceRamada Plaza Conference Center, 390 Forsgate Drive, Monroe Township, NJ 08831
- David Aughtry and Phil Karter present ‘Witnesses, Whistleblowers and Protecting the Cause’Loews Chicago O’Hare Hotel, 5300 North River Road, Rosemont, IL 60018, May 9, 2017
- Criminal Tax WorkshopLas Vegas
- Chamberlain Hrdlicka lawyers to co-present at Tax Executives Institute 2016 Audits & Appeals Seminar
- Chamberlain Hrdlicka tax attorney to advise lawyers on helping a client facing an IRS audit
- Philadelphia tax attorney Philip Karter to present advice on responding to new IRS rules for Information Document Requests (IDRs)Grand Hyatt Atlanta in Buckhead, Atlanta, GA, October 19 to 23, 2015
- Preparing Witnesses - The Good, Bad & UglySan Francisco, CA, May 19, 2015
- Preparing Witnesses - The Good, Bad & UglyNew York, N.Y., May 21, 2014
- The Four Seasons Philadelphia, May 30, 2012
- Leveraged Partnership Transactions and Tax Opinions Since Canal Corp.Structuring Transactions and Tax Advisor Engagements to Withstand IRS Scrutiny and Avoid PenaltiesJune 22, 2011
- Resolving IRS Tax Controversies (Chicago)Current Developments and Hot TopicsApril 12, 2011
- Chicago Tax ClubEconomic Substance And International Tax Law Following CodificationOak, April 11, 2011
- Mayo Foundation v. U.S.: Supreme Court Applies Chevron Analysis to Tax CasesUnderstanding the Implications of Giving Deference to IRS RegulationsMarch 23, 2011
- Resolving IRS Tax Controversies (Las Vegas)Current Developments and Hot TopicsLas Vegas, NV, February 15, 2011
- Pennsylvania Bar Institute - When to Hold Them and When to Fold ThemProtecting Tax Accrual Workpapers and Tax Opinions from the IRS; Disclosing Tax Opinions for Penalty ProtectionPennsylvania Bar Institute, May 29, 2008
Publications
Publications
- Tax Notes, September 11, 2017