Our Tax Litigation Practice
Brown, PC is a boutique law firm that represents carefully selected clients in complex, high-stakes tax and white collar defense litigation. Our clients have included multi-national corporations, members of the Forbes 400, Hall of Fame professional athletes, Grammy Award winning artists, entrepreneurs, C-level executives, and licensed professionals, and we have successfully represented them in some of the most complex cases ever pursued by the federal government.
Our tax clients come to us from all regions of the United States and across the globe. We handle a broad range of tax matters including criminal tax investigations and prosecutions; civil tax litigation in the U.S. Tax Court, U.S. Court of Federal Claims, and U.S. District Courts; IRS audits and appeals; IRS collection matters; International Tax and Offshore Compliance cases; and state and local tax disputes.
We are in high demand as expert witnesses and are often called upon to represent licensed tax professionals including attorneys and CPAs when they are targeted by the IRS or Department of Justice. We have a great deal of experience in IRS Global High Net North Industry (GHWIG) cases, and are particularly adept at achieving successful outcomes in complex, high stakes, and contentious tax disputes.
Examples Of IRS Collection Cases We Have Handled
We have represented clients in some of the largest tax cases ever pursued by the IRS or the U.S. Department of Justice, and successful outcomes recently achieved for clients include the following:
- Persuading the IRS and U.S. Department of Justice Tax Division to decline criminal tax prosecution of:
- A billionaire targeted in a $60,000,000 gift tax fraud case.
- A CFO targeted in a $300,000,000 payroll tax fraud case.
- A prominent physician who had not filed a tax return for nearly a decade.
- A high profile attorney targeted for personal income tax evasion.
- Keeping a $3,100,000 Trust Fund Recovery Penalty from being assessed against a company vice president.
- Negotiating installment agreements for:
- A hospital with $8,000,000 payroll tax delinquency.
- A construction company with a $5,100,000 payroll tax delinquency.
- Persuading an IRS Revenue Officer to release levies on accounts receivable that crippled the second career business of a Hall of Fame former professional athlete, with a multi-million dollar tax delinquency.
- Achieving no change for multiple clients in large IRS audits.
- Navigating multiple clients through IRS Offshore Voluntary Disclosure.
Our White Collar Defense Practice
We represent clients throughout the United States at all stages of complex government enforcement and white collar criminal matters including pre-indictment, U.S. District Court proceedings, appeal, and post-conviction litigation. Many of the cases we handle involve multiple government investigative agencies and parallel criminal, civil, and regulatory matters.
Successful outcomes recently achieved for clients include the following:
- Persuading the government to decline prosecution of:
- A Chinese born Fortune 100 executive targeted for espionage, obstruction of justice, and tax evasion.
- A CEO targeted for insider trading.
- The founder of a large franchisor for mail and wire fraud.
- A foreign born entrepreneur targeted for tax and Foreign Corrupt Practices Act violations.
- Defeating the government at trial on nine counts of money laundering, one count of conspiracy to structure monetary transactions, and a $17,000,000 asset forfeiture count.
- Obtaining pre-trial diversion for one of the country’s premier collectors targeted for federal firearms charges.
- Negotiating a plea agreement that provided for probation for a client targeted in an international art fraud and money laundering scheme.
Being involved in a large tax dispute or targeted in a white collar criminal investigation can be extremely stressful We do everything we can to minimize that stress. We communicate. Our team of professionals take client calls whenever possible, and if they cannot, calls are returned and emails are responded to promptly. When circumstances require it, our firm’s founder, Lawrence Brown, is available to clients outside of normal business hours.
Our clients are extremely successful. When we need their input, we make not to waste their time. Similarly, while we will do anything and everything within ethical boundaries to achieve our client objectives, we are surgically precise and efficient with the use of our time and consequently our client funds. We do not have multiple layers of billing, so common in larger firms. Discretion and client confidentiality are at a maximum.