Tax Controversies & Planning

The Tax Controversies & Planning Group at Henderson, Caverly, Pum & Trytten LLP brings a wealth of experience to bear in representing businesses and individuals before all federal, state and local taxing authorities. The Group also assists clients in planning and consummating business and real estate transactions in a manner designed to minimize tax impact.

The members of the Group deal with the Internal Revenue Service in defending Revenue Agent audits, in prosecuting protests with the IRS Appeals Office, and in litigating tax cases in the United States Tax Court, the United States District Courts, and the United States Claims Court. We handle sensitive disclosure cases, such as those involving foreign account tax compliance and tax shelters challenged by the taxing authorities. We handle criminal tax defense matters in the investigative stages and at trial. We advise professional tax preparers in minimizing their exposure to claims and potential claims by taxing authorities and by clients alleging errors and omissions. We also assist professional tax advisors as expert witnesses in contested cases arising from disputed tax matters.

At the state level, we represent clients in state income tax matters ranging from Franchise Tax Board audits to hearings before the full State Board of Equalization. We have extensive experience with residency issues and apportionment issues. We handle sales and use tax audits and administrative sales and use tax appeals before the State Board of Equalization. We have extensive experience in the sales and use taxes applicable to vessels and aircraft, and related exemptions. We also represent clients before the California Employment Development Department in employment tax matters.

Our California property tax practice is statewide. We have represented taxpayers before the Assessor’s Offices and Assessment Appeals Boards in most of the major California counties. We handle both real property and business personal property audits and administrative appeals. Our experience in the property tax arena includes representation of public companies and other clients in the health care, life sciences, energy, airline, medical research, communications, entertainment, manufacturing and real estate industries.

We handle litigation of state and local tax matters in the California Superior Courts and Courts of Appeal.

On the transactional side, we advise on business and real estate sales and exchanges, and corporate, limited liability company and partnership restructuring, all with an eye toward minimizing income, sales and use, and property tax impacts.

J. Clancy Wilson has been practicing in the tax area for 40 years and brings broad and deep experience to recognizing and resolving tax issues for the firm’s clients.