Tax Controversy


  • IRS Individual Audit Defense

    Successful defense of a family-owned manufacturing and real estate business based in Hawaii and Texas, settling income tax issues and avoiding potential gift tax assessments involving tens of millions of dollars.

  • IRS Appeals

    Prepared and filed written arguments with IRS Appeals protesting an auditor’s denial of a charitable deduction of approximately $500,000 by the taxpayer who gave closely-held stock to charity. The



In addition to our broad experience in Business and Estate Tax Planning, the Firm has an active Tax Controversy practice. Munsch Hardt attorneys represent major clients, including individuals and business entities of all types and sizes before the Internal Revenue Service, as well as the Texas Comptroller’s Office. Whether at audit, appeals or in court, our team has successfully obtained favorable settlements for clients active in the financial, investment, energy, retail, hospitality, health care and insurance industries to name a few. 

Our Firm’s Tax attorneys have a thorough understanding of IRS practice and procedure, a working knowledge of substantive tax areas, and the skill to advocate a position before the IRS or, if necessary, in court. Regardless of the situation, our attorneys strive to minimize the scope of such disputes, resolving them as quickly and cost-effectively as possible. 

In the initial stages of an audit, our Tax Controversy attorneys quickly identify significant issues and develop strategies to effectively achieve our clients’ objectives. We advise on responding to information requests and summonses, establish procedures to identify and protect privileged documents, prepare witnesses and establish appropriate document retention procedures to preserve evidence. Munsch Hardt Tax attorneys possess the skills necessary to negotiate a settlement, as well as the experience and foresight to position the matter for litigation. 

By working to resolve disputes at the earliest possible stage, we are often able to reach favorable outcomes for our clients without the additional costs, distraction and publicity that unnecessarily accompany formal tax disputes. In litigated matters, we bring to bear a team of experienced tax litigators who understand both the substantive tax issues and how to present a case effectively.