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Tax Controversies

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Overview

Since 1935, Ivins, Phillips & Barker has represented clients in tax controversies in almost all areas of domestic and international tax law, and at every level of the administrative process and the courts. To learn more about our tax controversy practice, please visit our pages on IRS Audit Defense, IRS Appeals Proceedings, and Tax Litigation.

Areas Of Concentration

Attorneys

Practice Contact

James E. Brown

Partner

Attorneys

Eric R. Fox

Partner

Harry L. Gutman

Harry L. Gutman

Of Counsel

Jonathan L. Holbrook

Jonathan L. Holbrook

Partner

Percy Lee

Of Counsel

Jeffrey E. Moeller

Jeffrey E. Moeller

Partner

Leslie J. Schneider

Leslie J. Schneider

Partner

Eric Solomon

Partner

Robert H. Wellen

Robert H. Wellen

Partner

News & Events

News

IPB Recognized in Best Law Firms 2025® | 11.07.2024
Twenty-Two IPB Attorneys Recognized in Best Lawyers in America and Ones to Watch 2025 Editions | 08.15.2024
IPB Recognized in Best Law Firms® for 2024 | 11.02.2023
IPB Achieves Mansfield Certification Plus for the Second Time | 10.10.2023
Eric Solomon Named "Lawyer of the Year" by Best Lawyers®; Twenty-Three IPB Attorneys Recognized in Best Lawyers in America and Ones to Watch 2024 Editions | 08.17.2023
Bob Wellen Interviewed for On Tax Podcast | 06.07.2023
Robert H. Wellen, Distinguished Tax Expert and IRS Official, Returns to Ivins, Phillips & Barker | 06.06.2023
2023 Chambers USA Guide Recognizes Four IPB Partners Individually, As Well As Tax And Benefits Practices | 06.01.2023
Eric Solomon, Esteemed Tax Authority, Joins Ivins, Phillips & Barker | 05.08.2023
Jon Holbrook Becomes Partner at IPB | 01.31.2023
IPB Recognized in US News & World Report's Best Law Firms for 2023 | 11.03.2022
IPB Achieves Mansfield Certification Plus | 05.05.2022
Tom Cryan Speaks With Law360 About Joining IPB | 03.28.2022
IPB Welcomes Tom Cryan to Our Benefits & Compensation Practice | 03.23.2022
IPB Recognized in US News & World Report's Best Law Firms for 2022 | 11.04.2021
Thirteen IPB Attorneys Recognized by Best Lawyers | 08.19.2021
The Legal 500 Recognizes Ivins, Phillips & Barker as a Top US Firm for 2021 | 06.11.2021
IPB's Tax and Benefits & Compensation Practices Recognized Along with Four IPB Partners in the Latest Chambers USA Guide | 05.20.2021
Linda Kotis and Ken Jefferson Write About Mann vs. U.S. Decision | 03.24.2021
Ken Jefferson Presents to the ABA on Audit Risk for Estate and Gift Tax Returns | 03.19.2021
Les Schneider Listed in the Top Tier by Chambers Global Guide 2021 | 02.19.2021
Pat Smith Files Merits Stage Amicus Brief in the Supreme Court in the CIC Services case | 07.17.2020
IPB Partners Present to TEI Dallas Chapter on Attorney/Client Privilege Issues | 09.25.2019
Best Lawyers 2020 Edition Recognizes Eleven IPB Attorneys | 08.15.2019
Jamie Brown Speaks to TEI's New England Chapter | 04.08.2019
Pat Smith Quoted in Tax Notes on IRS Motion to Dismiss in Suit by Montana Governor Challenging IRS Elimination of Donor Disclosure Requirements | 02.27.2019
Pat Smith Quoted in Tax Notes on Third Circuit Case on CFC Loan Guarantees | 12.11.2018
Pat Smith Quoted in Tax Notes on Anti-Injunction Act Issue in Sixth Circuit Case CIC Investors | 11.05.2018
Pat Smith Quoted in Tax Notes on Supplemental Briefs in Altera on Statute of Limitations Issue | 10.11.2018
Jamie Brown Speaks on IRS Audits of Midsize Businesses | 10.11.2018
Pat Smith Quoted in Tax Notes on Third Circuit Appeal of Tax Court’s Decision in SIH Partners | 10.04.2018
Pat Smith Quoted in Tax Notes on Statute of Limitations Issue in Altera | 10.02.2018
Law360 publishes Pat Smith’s article on the D.C. Circuit Good Fortune Shipping opinion in the context of withdrawn Ninth Circuit Altera opinion | 09.06.2018
Ten IPB Attorneys Named to 2019 Best Lawyers in America | 08.15.2018
Pat Smith Quoted in Tax Notes on D.C. Circuit decision in AICPA v. IRS | 08.15.2018
Pat Smith Quoted in Both Tax Notes and the Daily Tax Report On Possible Next Steps in Altera Case | 08.07.2018
Pat Smith Quoted in a Daily Tax Report Follow-Up on the Ninth Circuit Altera Decision | 08.03.2018
Pat Smith Quoted in Both Tax Notes and the Daily Tax Report on Ninth Circuit Altera Decision | 07.25.2018
Pat Smith quoted in both Tax Notes and the Daily Tax Report about why the choice of Judge Kavanaugh for the Supreme Court is bad news for taxpayers | 07.11.2018
Pat Smith quoted in both Tax Notes and the Daily Tax Report on the retirement of Supreme Court Justice Anthony Kennedy | 06.28.2018
Ivins Wins Full Concession of $3.6 Million Tax Court Case | 06.05.2018
Pat Smith Quoted in Tax Notes on Court Decision Upholding IRS Denial of Access to Appeals | 05.16.2018
IPB Ranked by Chambers USA as a Leading Firm | 05.2018
Jamie Brown and Heléna Klumpp Spoke at TEI’s 2018 Audits & Appeals Seminar | 04.30.2018
Eleven IPB Attorneys Named as 2018 DC Super Lawyers | 04.2018
IPB Attorneys Spoke at the FBA Annual Tax Law Conference | 03.09.2018
Pat Smith Quoted in Tax Notes | 03.06.2018
Pat Smith Quoted in Tax Notes | 02.14.2018
IPB Attorneys Teach Tax Strategies for Artists | 02.05.2018
Leslie Schneider Quoted in The Washington Post re: Prepaid Property Taxes | 01.23.2018
Pat Smith Quoted in Bloomberg BNA Daily Tax Report article | 01.22.2018
LB&I Instructs Field Agents on How to Audit the Subpart F Manufacturing Exception | 01.11.2018
IPB Attorney Patrick Smith Spoke at D.C. Bar | 01.10.2018
Leslie Schneider Quoted in Wall Street Journal re: IRS Prepayment Rule | 12.29.2017
"The Problem with Wearing Two Hats" Cited by Senator Wyden | 12.21.2017
Patrick Smith to Speak at D.C. Bar | 12.14.2017
IPB Attorney Pat Smith Quoted in Tax Notes re: Altera Makes Its Mark | 11.13.2017
IPB Selected as One of the 2018 Best Law Firms in America | 11.2017
Eric Fox and Jamie Brown Spoke on Tax Controversy Podcast | 10.19.2017
IPB Attorney Pat Smith Quoted in Tax Notes re: Treasury to Limit IRS's Ability to Use Outside Attorneys | 10.12.2017
Pat Smith Quoted re Maze v. IRS | 07.14.2017
Mindy Herzfeld authors "The Case Against BEPS" | 06.19.2017
TEI Conferences | 06.2017
Doug Andre Quoted re: Expatriation | 05.10.2017
Ten Ivins Attorneys Named as 2017 DC Super Lawyers | 04.2017
Hank Gutman Speaks re: Tax Reform | 04.2017
Ivins Attorney Pat Smith Quoted in Tax Notes re: Section 883 Regulations | 03.31.2017
Ivins Attorney Teaches "Tax Strategies" Class in Pro Bono Partnership | 03.22.2017
Ivins Attorneys Speak re Protecting Sensitive Tax Documents | 02.24.2017
IRS Identifies High-Priority Enforcement Issues | 02.10.2017
Ivins Attorney Pat Smith Quoted in Tax Notes re: Effect of Regulatory Freeze | 01.27.2017
Ivins Attorney Pat Smith Quoted Re: Regulatory Freeze | 01.24.2017
Ivins Attorney Pat Smith Quoted in Tax Notes re: QinetiQ Decision | 01.09.2017
Hank Gutman Speaks at TEI Annual Meeting | 12.14.2016
Hank Gutman Featured in TEI's "Ask the Expert" | November/December 2016
Taxation of Business Income - Client Alert | 11.18.2016
Section 385 Regulations-Corporate Client Alert | 11.14.2016
IPB Selected as One of the 2017 Best Law Firms in America | 11.2016
Ivins Attorney Pat Smith Quoted in Tax Notes re QinetiQ case | 10.28.2016
Pat Smith Quoted re Debt-Equity Regulations under Section 385 | 10.14.2016
Ivins Attorney Pat Smith Quoted in Tax Notes re Multiple Acquisition Anti-Inversion Rule | 10.13.2016
Pat Smith Quoted in Tax Notes re Fourth Circuit QinetiQ Case | 10.03.2016
Pat Smith Quoted in Tax Notes Regarding Altera Decision | 09.13.2016
Eleven Ivins Attorneys Named to 2017 Best Lawyers in America® | 08.16.2016
Former Justice Department Lawyer Rejoins Ivins' Premier Tax Controversy Team | 08.10.2016
Pat Smith Quoted in Wall Street Journal and Tax Notes Articles | 08.05.2016
Ivins Named to Above The Law's Tax Firm Power Rankings | 07.20.2016
Pat Smith Quoted in Tax Notes re Tax Court's Decision in Altera | 06.29.2016
Pat Smith Quoted in Tax Notes Regarding Regulation Text | 06.27.2016
Pat Smith Quoted Regarding Florida Bankers Supreme Court Case | 06.07.2016
Treasury Proposes New Reporting Rules for Foreign-Owned Disregarded Entities | 05.11.2016
Pat Smith Quoted in BNA's Daily Tax Report on Petition for Certiorari in Florida Bankers Association | 04.28.2016
Pat Smith Quoted in Tax Notes on Implications of Tax Court’s Altera Decision | 04.19.2016
Pat Smith Quoted in Tax Notes re: Ax v. Commissioner | 04.11.2016
Pat Smith Quoted in Tax Notes on Starr International Case | 03.28.2016
Pat Smith Quoted in Tax Notes re: Starr International | 03.02.2016
Pat Smith was Quoted in Both the Bloomberg BNA Daily Tax Report and Tax Notes on the IRS Decision to Appeal its Loss in the Tax Court in Altera to the Ninth Circuit | 02.24.2016
Ivins Attorney Pat Smith Quoted in Tax Notes re: Deficiency Notices | 02.16.2016
Ivins Attorney Pat Smith Quoted in Tax Notes re: Monetary Relief not Available to Starr | 02.04.2016
Pat Smith’s Most Recent Article Published in Tax Notes | 12.21.2015
Pat Smith Speaks to DC Bar on “Challenging Tax Regulations" | 12.08.2015
Ivins Partner Named to Washingtonian 2015 Top Lawyers | 12.2015
Leslie Schneider Speaks at the TEI Chapter Meeting in Tulsa, OK | 11.12.2015
Patrick Smith, Ivins, Phillips & Barker, Tax Notes, February 4, 2016 Monetary relief not available to Starr International and Bank Groups Petition for Cert Over Reporting for Nonresidents | 11.02.2015
Leslie Schneider Speaks at the TEI Ft. Worth Chapter Meeting | 10.28.2015
Leslie Schneider Speaks at the TEI Annual Meeting in Dallas TX | 10.19.2015
Ivins Advises Bayer on $2 Billion IPO of Material Science Business | 10.08.2015
Pat Smith Quoted in Tax Notes on Starr International Case | 09.22.2015
Jeff Moeller Co-Chairs Bloomberg BNA Tax Credit Symposium | 09.21.2015
Eight Ivins Attorneys Named to 2016 Best Lawyers in America | 08.18.2015
Pat Smith Featured in Top 10 Most Downloaded Administrative Law Articles for July 2015 | 08.03.2015
Patrick Smith Quoted in BNA Daily Tax Report on the Altera Decision | 07.31.2015
Ivins Attorney, Patrick Smith, Quoted in Law360 Article on the Altera Decision
Pat Smith Featured in Top 10 Most Downloaded Administrative Law Articles | 07.14.2015
Benjamin Grosz Interviewed by U.S. News & World Report on 529 Plans | 06.17.2015
Ivins Attorney Pat Smith was Quoted in a Law 360 article | 05.26.2015
Pat Smith Participated in Tax Court Judicial Conference | 05.21.2015
Jeff Moeller Speaks at 2015 TEI Audits & Appeals Seminar | 05.20.2015
Ivins Attorneys Speak at ABA Tax Section 2015 May Meeting | 05.2015
Nine Ivins Attorneys Named as 2015 DC Super Lawyers | 04.26.2015
Benjamin Grosz Speaks at American Bar Association Young Lawyer Institute | 04.16.2015
Pat Smith Quoted on Supreme Court's Decision in Direct Marketing Association | 03.30.2015
Ivins Attorneys Speak at TEI 65th Mid-Year Conference | 03.25.2015
Les Schneider Speaks at TEI Carolinas Chapter Meeting | 03.20.2015
Patrick Smith Comments on Tax Notes Article re: Discretionary Actions | 03.16.2015
Ivins Attorneys Speak at Federal Bar Association Tax Law Conference | 03.06.2015
Ivins Attorneys Comment on Codified Economic Substance Doctrine | 02.02.2015
Ivins Attorney Lisa Milot Quoted re Tax Court Decision in Perez v. Commissioner | 01.22.2015
Nine Ivins Attorneys Named to 2015 Best Lawyers in America® | 08.21.2014
Ivins Attorneys Lecture on Life Science Industry Tax Issues | 05.29.2014
Jeffrey Moeller and Alex Sadler Speak at Tax Executives Institute (TEI) Session | 05.22.2014
Eight Ivins Attorneys Named as 2014 DC Super Lawyers | 04.2014
Ivins Attorneys Speak at FBA Tax Law Conference | 02.28.2014
IP&B Client Boston Properties Wins Summary Judgment in DC Tax Litigation | 01.24.2014
Nine Ivins Attorneys Named to 2014 Best Lawyers in America | 08.21.2013
Douglas Andre, Speaker, FBA Teleconference re: PPL Corp. v. Commissioner | 06.03.2013
Chambers USA Ranks Ivins as a Leading Global and DC Tax & Benefits Firm | 05.24.2013
Six Ivins Attorneys Named as 2013 DC Super Lawyers | 04.28.2013
Funeral Industry Comments on Proposed Regs on Net Investment Income Tax | 03.28.2013
Douglas Andre Moderates DC Bar Panel on International Tax Disputes | 03.20.2013
Brenda Jackson-Cooper Speaks at DC Bar Estate Planning Taxation Section: "Estate Planning for Same-Sex Couples" | 03.14.2013
Robert B. Stack Appointed U.S. Deputy Assistant Treasury Secretary for International Tax Policy | 03.08.2013
Ivins Attorneys Speak at Federal Bar Association Tax Law Conference | 03.01.2013
Practising Law Institute Consolidated Tax Return Regulations 2013 | 02.26.2013
ABA Tax Section Teleconference: Intra-Group Restructurings | 02.06.2013
Benjamin Grosz Speaks at DC Bar Estate Planning Committee on the Use and Taxation of Powers of Appointment | 01.22.2013
Les Schneider Testifies at Public Hearing on the Proposed Regulations | 01.07.2013
Ivins Comments on Proposed Regulations | 12.2012
Amicus Brief Filed re: PPL Corporation and Subsidiaries v. Commissioner of Internal Revenue | 12.14.2012
Ivins Attorneys Speak at TEI New Orleans Chapter | 11.27.2012
Ivins Attorneys Speak at TEI Annual Conference | 10.30.2012
Chambers USA Ranks Ivins as a Leading DC Tax and Benefits Firm | 2012
Fiduciary Duties in the Termination of Defined Benefit Pension Plans | 06.2012
Pat Smith to Moderate Panel on Post-Mayo Developments at Federal Bar Association Insurance Tax Seminar | 05.31.2012
Ivins Secures Post-Mayo Victory in Federal Circuit Invalidating Treasury Regulation -- Dominion Resources v. United States | 05.31.2012
Ivins Attorneys Named to 2012 Washington DC Super Lawyers | 05.2012
Ivins Attorneys Speak at Federal Bar Association Tax Law Conference | 03.02.2012
Ivins Attorneys Speak at ABA 2012 Tax Section Meeting | 02.17.2012
Ivins Attorney Presents at BNA CITE International Tax Seminar | 12.07.2011
Ivins Attorneys Named Best Lawyers in Washington DC | 12.01.2011
Ivins Attorney Presents to Young IFA Network on Foreign Currency Tax Issues Webinar | 11.30.2011
Ivins Attorneys Speak at 66th TEI Annual Conference | 11.02.2011
Ivins Named as Tier 1 Firm in U.S. News "Best Law Firms" Ranking | 11.01.2011
Ivins Attorneys Speak at 2011 ABA Joint Fall CLE Meeting | 10.20.2011
Ivins Attorneys Speak at Fort Worth TEI Meeting | 09.28.2011
Ivins Attorneys Speak at Cincinnati TEI Seminar | 09.19.2011
Ten Ivins Attorneys Named to 2012 Best Lawyers in America | 08.31.2011
Patrick Smith Quoted in Tax Analysts Article on Omissions from Gross Income Cases | 08.22.2011
Ivins Attorneys Comment on Guidance under Section 355 | 08.01.2011
Ivins Attorney Comments on Guidance under Section 909 | 06.01.2011
Ivins Attorneys Named to 2011 Washington DC Super Lawyers | 05.08.2011
Ivins Attorneys Speak at 2011 ABA Tax Section May Meeting | 05.06.2011
Ivins Attorneys to Speak at the FBA Annual Tax Law Conference | 02.22.2011
Ivins, Phillips & Barker Celebrates 75th Anniversary | Summer 2010
Ivins Named as First-Tier Firm in U.S. News "Best Law Firms" Rankings | 06.15.2010
Leslie Schneider Comments on Licensing Fee Decision | 03.29.2010
Leslie Schneider Comments on Bonus Compensation Plan Liability | 03.08.2010
Ten Ivins attorneys named to the 2010 Best Lawyers in America | 2010
Leslie Schneider Comments on Proposal to Repeal LIFO | 09.30.2009
Ivins Lawyers Address Silicon Valley Tax Directors Group Luncheon | 09.24.2009
Ivins Lawyers Present Article to BNA International Advisory Board Meeting | 08.20.2009
Identifying 10 Leading Tax Lawyers | 07.18.2005
IP&B Wins Closely-Watched Case in Supreme Court | 06.04.2001
"One of the Last Pristine Tax Boutiques" | 02.21.2000

Publications

With Altera Appeal Still Pending, IRS Signals Intent to Re-Open Audits of Cost-Sharing Issue | 08.08.2019
Tax Court Litigation Basics | 08.2018
Guide to Civil and Criminal Tax Penalties | 08.2018
"The Problem With Wearing Two Hats" | 11.06.2017
Why "Rite Aid" Was Right | 04.17.2017
Ivins Attorney Doug Andre Quoted Regarding Expatriation | 02.09.2017
Final Regulations Issued for Foreign-Owned Disregarded Entities | 12.22.2016
Marvel and United Dominion's Dangerous Dictum | 10.10.2016
"Defending Transfer Pricing Audits Under the IRS's New Roadmap" | April 28, 2014
"Coming Conflicts: Proposed U.S. Transfer Pricing Services Regulations and the Treatment of Intangibles" | September 30, 2004
Patrick Smith Recently on List of Top Ten Downloads for U.S. Administrative Law e-Journal | 08.21.2015
Pat Smith's Two-Part Blog on Florida Bankers Association v. Treasury Department Featured in Procedurally Taxing | 08.18.2015
Ivins Attorney Pat Smith's Recent Blog Post on Altera Decision | 08.06.2015
Pat Smith Featured in Top 10 Most Downloaded Administrative Law Articles | 07.14.2015
Pat Smith Blog Post on Michigan v. EPA Featured in Procedurally Taxing and SCOTUSBlog | 07.02.2015
Patrick Smith Posts at TaxProf Blog on D.C. Circuit Z Street opinion and is quoted by Bloomberg BNA Daily Tax Report on the same subject | 06.2015
Summary Posted TaxProf Blog of Patrick Smith's Recent Tax Notes Article | 06.10.2015
Ivins Attorney, Patrick Smith, Guest Blogger re: Supreme Court's Direct Marketing Decision | 06.08.2015
Challenges to Tax Regulations: The APA and the Anti-Injunction Act | 05.25.2015
IRS Issues Guidance Regarding Credits and Refunds of Tax Withheld from International Payments | 04.29.2015
Patrick Smith, A Thank You for Being One of the "Finest Guest Posters" | 04.06.2015
Ivins Attorney, Patrick Smith, Guest Blogger re: Perez v. Mortgage Bankers Association | 03.10.2015
Ivins Attorney, Patrick Smith, Guest Blogger, re: Supreme Court's Direct Marketing Case | 03.04.2015
Contingent Purchase Price, Contingent Liabilities and Indemnities in Taxable Acquisitions | 11.06.2014
Ivins' Attorney, Patrick Smith, Guest Blogger re: Changes in Agencies' Interpretations ... | 10.08.2014
Ivins Attorneys Quoted in Tax Notes Today on Inversion Guidance | 09.24.2014
Interest Netting Between Merging Corporations | 07.08.2014
The End of Circular 230 Disclaimers | 06.11.2014
Brand X, 3M, and Legal Restrictions On the Payment of Income | 03.24.2014
District Court Misapplies APA in Florida Bankers Association | 02.17.2014
BEPS Update: Country-by-Country Reporting | 02.05.2014
IPB Attorneys Comment on OECD BEPS-Related Initiative | 02.2014
Prototypes and Depreciable Property: An Attempted Distinction | 01.20.2014
May Regulations That Violate the APA Be Remanded to the IRS? | 10.07.2013
Quality Stores and the Status of Revenue Rulings | 09.09.2013
Note, Incentivizing Conservation: Restructuring the Tax-Preferred Easement Acceptance Process to Maximize Overall Conservation Value | 08.2013
Chevron's Conflict with the Administrative Procedure Act | 06.25.2013
PPL: How to Determine Whether a Foreign Tax Is Creditable | 03.18.2013
U.S. IRS, Lockheed fight over R&D 'rocket science' tax break (quoted in article by Patrick Temple-West) | 01.25.2013
The APA's Arbitrary and Capricious Standard and IRS Regulations | 07.16.2012
Requests for Admission in Federal Tax Litigation: Uses, Limitations, Rules, and Strategic Considerations | February-March 2012
Appeals Restrictions in Cornyn Legislation Get Mixed Reaction | 04.2012
Standards for Tax Court Review in Equitable Innocent Spouse Cases | 02.20.2012
Expedited Opt-Out Needed for OVDI Participants Who Owe No Tax | 01.30.2012
Federal Circuit Clarifies Third-Party Return Information Disclosure Exception | 01.2012
The APA’s Reasoned-Explanation Rule and IRS Deficiency Notices | 01.16.2012
Is the Anti-Injunction Act Jurisdictional? | 11.28.2011
Overcoming Appeals' Bad Rap (quoted in article by J. Coder) | 09.2011
Navigating the Research Credit | 09.2011
DC Circuit: 'The IRS Is Not Special' | 08.30.2011
Life After Mayo: Silver Linings | 06.20.2011
Mayo and Chenery: Too Much of a Shift in Rationale? | 10.25.2010
Gaps in the Seventh Circuit's Reasoning in Lantz | 09.27.2010
Omissions From Gross Income And the Chenery Rule | 08.16.2010
Recovery of Madoff-Related Tax Losses | 12.2008
Leading Lawyers | 07.18.2005

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