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
- November 12, 2019
- November 6, 2019
- US News, November 2019
- October 30, 2019
- October 21, 2019
- Main Line Today, October 10, 2019
- Law360, September 10, 2019
- Attorneys with national law firm Chamberlain Hrdlicka have been selected to the 2019 Texas Super Lawyers listSeptember 3, 2019
- September 3, 2019
- Metro Atlanta CEO, August 19, 2019
- August 15, 2019
- Atlanta Journal-Constitution and Daily Report, July 25, 2019
- Metro Atlanta CEO, July 18, 2019
- June 26, 2019
- Daily Report, June 20, 2019
- The Legal Intelligencer
- May 30, 2019
- May 21, 2019
- May 10, 2019
- The Legal Intelligencer
- The Supreme Court last year allowed states to tax online retail sales. What kinds of sales, and how to tax them, remains a complicated question.National Journal, April 25, 2019
- April 18, 2019
- April 17, 2019
- March 7, 2019
- February 7, 2019
- Blockt, February 3, 2019
- CNBC, January 30, 2019
- Trusts & Estates, December 17, 2018
- Atlanta Business Chronicle, November 16, 2018
- Chamberlain Hrdlicka again named a "Best Law Firm" by US NewsNovember 1, 2018
- Accounting Today, October 30, 2018
- Bloomberg Tax, October 24, 2018
- October 12, 2018
- October 12, 2018
- Bloomberg BNA, October 4, 2018
- Attorneys with national law firm Chamberlain Hrdlicka have been selected to the 2018 Texas Super Lawyers listSeptember 20, 2018
- Texas Lawyer, September 17, 2018
- Bloomberg BNA, September 7, 2018
- Bloomberg BNA, September 4, 2018
- Main Line Today, August 8, 2018
- Atlanta Journal-Constitution, August 5, 2018
- Metro Atlanta CEO, August 2, 2018
- February 2018
- 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
- Accounting Today, October 4, 2017
- Chamberlain Hrdlicka Attorneys Ranked in Construction, Litigation – Construction, Eminent Domain & Condemnation, Employee Benefits (ERISA), Government Relations, Immigration, Tax, Litigation and Controversy - Tax, and Trust & Estates CategoriesAugust 2017
- 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
- Attorneys Ranked in Tax, Construction, Trust and Estates, Employee Benefits and Immigration CategoriesJune 22, 2017
- 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
- Firm and eight attorneys ranked on state and national levels in tax, tax controversy, tax fraud, labor & employment and immigration categoriesJune 6, 2017
- Chamberlain Hrdlicka lawyer discussed preparing witnessesMay 22, 2017
- Chamberlain Hrdlicka senior counsel discusses attorney-client privilege at annual anti-fraud conference
- 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
- Atlanta Business Chronicle, August 11, 2006
- July 11, 2006
Presentations
Seminars & Presentations
- Philadelphia, PA
- "The Devil is In the Details - Current Developments Affecting Individuals and Businesses" – Georgia Tax Forum Atlanta – Georgia Society of CPAsNovember 2019
- November 12, 2019
- November 6, 2019
- October 30, 2019
- October 23, 2019
- Chamberlain Hrdlicka West Houston Tax Forum on September 25 at Marriott WestchaseHouston Marriott Westchase, 2900 Briarpark Dr., Houston, Texas 77042, September 25, 2019
- "What, Me Deduct? What Every CPA Needs to Know About The Lender Case and Deducting The Costs of a Family Office" - Georgia Society of CPAs - North Atlanta ChapterSeptember 2019
- Chamberlain Hrdlicka September 19, 2019 West Loop (Galleria) Tax Forum - HoustonianThe Houstonian - 111 North Post Oak Lane, September 19, 2019
- June 20, 2019
- “No Good Deed Goes Unpunished: The IRS War on Conservation Easements” - 43rd Annual American Institute on Federal TaxationJune 2019
- “No Good Deed Goes Unpunished: The IRS War on Conservation Easements” – Georgia Society of CPAs Real Estate ConferenceJune 2019
- June 7, 2019
- May 29, 2019
- May 21, 2019
- Navigating the Maze – Understanding the Most Recent Changes to the Tax Cut and Jobs ActCobb Galleria, 2 Galleria Parkway, April 23, 2019
- Avoiding State Sales Tax Traps and Compliance Challenges, Navigating Audit IssuesMarch 21, 2019
- New Orleans, LA, March 12, 2019
- Chamberlain Hrdlicka McAllen Tax and Business Planning Seminar - March 4, 2019Home Ownership Center, 500 South 15th Street, McAllen, Texas 78501, March 4, 2019
- "Valuation Issues During Audits, Appeals, and Litigation -- Winning Valuation Cases" - Tax Executives Institute 2019 Global Audit & IRS Tax Controversy UpdateFebruary 2019
- Las Vegas, NV, December 13, 2018
- "Tiptoeing Through an Audit on Eggshells" - Georgia Society of CPAs IRS Solutions ConferenceDecember 2018
- "What Every Family Business and Family Office Needs To Know" - Mississippi Society of CPAs 2018 Annual Mississippi Tax InstituteDecember 2018
- November 15, 2018
- Philadelphia, PA, November 14, 2018
- Phoenix, AZ, October 25, 2018
- October 16, 2018
- Atlanta, GA, October 4, 2018
- July 24, 2018
- "Federal Tax Controversies – A Practical Approach"- Tax Executives Institute - Hilton Head, SCJune 2018
- “Let’s Party Like It’s 1986 – A Rousing Discussion of the New Tax Bill” - Quarterly Tax Forum - February 2018
- "Top Ten Tax Traps and How to Deal with Them" - Georgia Society of CPAs - Georgia Tax Forums - Atlanta and SavannahNovember 2017
- 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’May 9, 2017
- 33rd Annual National Institute on Criminal Tax Fraud and 6th Annual National Institute on Tax ControversyLas 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
- 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
- CPA Practice Advisor, October 28, 2019
- Legal Intelligencer, October 17, 2019
- Bloomberg Tax Management Memorandum and Daily Tax Report, April 10, 2019
- CCH Journal of Tax Practice & Procedure, January 22, 2019
- ABA Property Tax Deskbook, Pennsylvania Chapter2011-2018
- ALM Pennsylvania Tax Handbooked. 2013-2019
- PICPA's CPA Now, December 5, 2018
- Expat Network, September 2018
- Coindesk, April 2018
- AICPA Practical Tax Strategies, April 2018
- Wealth Management, October 18, 2017
- Tax Notes, September 11, 2017
- Tax Notes, September 11, 2017