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Hale Sheppard's practice focuses on tax audits, administrative tax appeals, tax litigation, tax collection defense, and international tax compliance and controversies. Tax Audits and Appeals. Mr. Sheppard regularly handles tax disputes before the IRS and various state revenue agencies. Typical cases involve audit representation, refund claims, abatement requests, applications for extensions to file statutory and regulatory elections, private letter ruling requests, audit reconsideration requests, penalty mitigation statements, formal protests before the IRS Appeals Office, and responses to document requests, summonses, and other governmental information-gathering devices. In addition to advising on traditional audits, Mr. Sheppard understands the unique rules applicable to many partnerships (i.e., the TEFRA procedures). Tax Litigation. If a tax dispute cannot be settled administratively, litigation often ensues. Mr. Sheppard has participated in suits before the U.S. Tax Court, U.S. Court of Federal Claims, and various U.S. District Courts. If the taxpayer prevails at trial, Mr. Sheppard often seeks reimbursement from the government for reasonable administrative and litigation costs. Mr. Sheppard's recent cases involved the deductibility of business expenses, hobby losses, mark-to-market elections for securities traders, assorted "tax shelters," international transfer pricing, reasonable executive compensation, transferee liability, passive activity loss limitations, alimony payments, trust fund recovery actions, civil fraud, and various employment tax issues. Tax Collection Defense. The job does not end when the IRS assesses taxes, penalties and interest. Indeed, many times Mr. Sheppard's work is just beginning. He has negotiated collection freezes, installment agreements, offers-in-compromise, and federal tax lien subordinations. He has also advised on transferee liability, as well as strategies for "responsible persons" held jointly liable for trust fund penalties. In resolving tax payment issues, Mr. Sheppard has participated in collection due process hearings, equivalent hearings, and the collection appeals program. International Tax Compliance and Controversies. Mr. Sheppard regularly counsels clients on IRS reporting requirements applicable to foreign financial accounts, domestic entities operating abroad, foreign entities doing business in the United States, expatriates, foreign trusts, and cross-border transfers. With respect to tax disputes, Mr. Sheppard defends clients against the unique information-gathering tools used by the government in the international context, including formal document requests, bilateral income tax treaties, and tax information exchange agreements. He has also negotiated multiple international tax settlements under various IRS programs, such as the Offshore Voluntary Compliance Initiative, Last Chance Compliance Initiative, and the Voluntary Disclosure Program. |
