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Even if tax-exempt, all companies doing business in the United States are subject to taxation under the Internal Revenue Code. The Department of Treasury and the IRS routinely review and audit a company’s tax position and raise concerns about the tax treatment of certain items.

We represent clients seeking to maintain compliance and avoid such government entanglement, as well as those already embroiled in a tax dispute. Whether as part of a deal or as part of a new enterprise, we help ensure that clients are complying with the Tax Code, whether through a review of existing law or through a request for a Private Letter Ruling from the IRS. When a dispute arises, we help clients navigate the administrative process to its conclusion and beyond, including litigation against the government in either the U.S. Tax Court or in the U.S. District Court nearest our client’s business.


Our services include:

  • Preparation and filing of requests for tax-exempt status for nonprofit and religious entities.
  • Consultation and preparation of tax opinions concerning taxation of certain business lines and activities.
  • Consultation concerning IRS Notices of Deficiency and attempts to levy.
  • Negotiation with the IRS concerning tax disputes.
  • Preparation and filing of requests for a Private Letter Ruling.
  • Consultation concerning the filing of refund requests with the IRS and the administrative process.
  • Litigation in the U.S. Tax Court over unpaid taxes.
  • When appropriate, federal refund litigation in U.S. District Court after the IRS disallows or ignores a timely claim for refund.

Contact Fritz E. Berckmueller, Partner 

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