Nationally ranked both as bond counsel and in tax controversy matters, we are uniquely qualified to advise and represent clients in IRS audits of tax-exempt bonds. Our tax lawyers have represented issuers, corporate borrowers and other interested parties in various tax-exempt bond tax audits involving a wide range of matters, including:
- advance refunding of governmental bonds
- private business use of a fiber optic network
- small issue manufacturing bonds, including capital expenditure questions
- multifamily housing bonds
- continuing care retirement facility
- governmentally-owned sports facilities
- section 6700 investigations
- requests for technical advice
- appeals to the Office of Appeals
Our ability to quickly analyze and advise clients on the highly technical issues often at the heart of such audits is greatly enhanced by the experience of our public finance team . Drawing on the experience of our transactional bond lawyers enables our tax litigators to deal efficiently and effectively with the myriad of issues arising from bond transactions.
Initial steps upon receipt of an IRS audit letter
Upon receipt of an IRS letter opening a bond examination, an issuer's first step should be to select experienced counsel. Although an issuer's first inclination may be to engage the bond counsel for the issue under examination, an issuer should consider whether that firm has sufficient experience with IRS audits, especially in the tax-exempt bond area, and the potential for any conflict of interest arising between the issuer's interests and those of the bond counsel.
Once an experienced counsel has been selected, such counsel can help the issuer determine whether the audit is random or targeted, and if the latter, the IRS's areas of concern.
- For the eleventh year, Corporate Board Member magazine reported that its survey of public company directors identified the firm as one of the top 25 corporate legal practices in the nation. Similar research by Corporate Board Member magazine identified the firm among the top 25 firms that general counsel would most likely hire for national matters. (2012)
- Consistently ranked by The Bond Buyer as one of the top ten bond counsel firms in the country.