Our Tax practice represents corporations, partnerships, limited liability companies and individuals in federal income tax planning with an emphasis on domestic corporate, partnership and real estate tax issues, including but not limited to organizational tax issues, and purchase and sale issues.

We also represent taxpayers before the Internal Revenue Service and the Federal Courts in the case of tax controversies, as well as clients in connection with state franchise tax and sales tax issues.

Additionally, we assist our clients in the establishment of non-profit corporations and in attaining 501©3 status with the Internal Revenue Service.

Capabilities include:

• Structure of stock, asset and merger transactions for maximizing most beneficial tax treatment.
• Preparation of partnership agreements and limited liability company organizational documents with an emphasis on federal tax issues.
• Structure of entity organization with a view to minimizing state franchise taxes.
• Structure like-kind exchanges both for real estate and other assets.
• Organization of venture capital partnerships.
• Consultation with other practice areas in the Firm to advise them of relevant tax issues with respect to matters before them.
• Prepare ruling requests on the tax consequences of certain transactions for presentation to the Internal Revenue Service.
• Representation of taxpayers in civil tax controversies before the Internal Revenue Service and the Tax Court, the Federal District Court, the Federal Appeals Court and the United States Supreme Court including preparation of protests and other communications in administrative hearings with the Internal Revenue Service and in conjunction with members of the litigation department.
• Preparation of all court filings and other related matters in the case of actual tax litigation.

Tony Newton handles the Firm's Tax practice.

• Represented a private corporation and rendered a tax opinion in a $1,500,000 reverse like-kind exchange.
• Represented a private corporation and rendered a tax opinion in a $1,400,000 tax-deferred merger of Texas corporation into a Washington corporation.
• Represented a private Louisiana limited liability company in a $3,100,000 tax-deferred stock exchange.
• Advised a private Texas limited liability company on use of net operating loss carryovers and issuing profits interests in connection with a $10,000,000 acquisition of a Delaware limited liability company.
• Represented a private Texas corporation in an IRS Private Letter Ruling request in connection with a conversion from an S corporation to Texas limited partnership.
• Represented an individual in a IRS Private Letter Ruling request relating to substantial compliance in connection with a $1,500,000 non-cash charitable contribution.