Our Tax Division provides services to a wide range of entities in the middle market, families, small businesses, and individuals.
We advise clients on all aspects of federal, state, local, and international tax matters.
Tax Opinion Letters offer a level of protection for a taxpayer considering taking a certain position on their return. A trained tax lawyer learns about the taxpayer and their proposed position, then analyzes the Code, Regulations, Rulings, case law, and other sources to determine if the position will reasonably be likely to be upheld. If the position leads to an audit then the opinion letter helps to justify the position from the outset of the audit with analysis and citation to authorities. Having the protection of an opinion letter will minimize the potential exposure of a tax position, and is an important tool in a toolbox for a risk-averse taxpayer.
Daniel O'Neil is your "Tax Law" attorney.