Bradley’s experienced tax controversy and litigation attorneys advocate for national, regional and local clients in a wide variety of federal, state and local tax disputes. Combining courtroom skills and litigation experience with the in-depth, technical knowledge of tax law, we are well- equipped to provide a full range of tax advocacy and litigation services. 

Bradley represents clients in all phases of federal tax disputes – from audit to administrative appeals to litigation. From Fortune 500 companies and private equity firms to closely held businesses and high-net-worth individuals, we represent individuals, businesses and nonprofit organizations facing every kind of tax dispute. Our clients are engaged in a range of diverse industries, including automotive, banking and financial services, computer software and technology, construction, engineering, entertainment, energy and natural resources, environmental, food services, healthcare, hospitality and lodging, insurance, retail, real estate, manufacturing, telecommunications, transportation, and many others.

Through our tax controversy and litigation practice, our attorneys regularly:

  • Assist clients with state and local tax audits, informal hearings, tax collection disputes, administrative appeals, and mediation and settlement conferences
  • Prosecute appeals of state and local tax assessments and claims for tax refunds before judicial courts at every level and administrative agencies and tribunals
  • Pursue protests and appeals of ad valorem real and personal property tax assessments, classifications, and real property tax exemptions before state and local boards of equalization and judicial courts
  • Negotiate tax amnesty and voluntary compliance agreements
  • Advise clients on complex federal tax issues with respect to structuring entity ownership and business transactions and developing solutions to federal tax compliance,
  • Represent clients in disputes with the Internal Revenue Service

We have the knowledge and experience to skillfully advise and represent clients in disputes with taxing authorities at the federal, state and local levels.

Our experience in tax controversy includes:

  • Income
  • Franchise and excise taxes
  • Sales and use taxes
  • Business and insurance taxes
  • Fuel taxes
  • Severance taxes
  • Real and personal ad valorem property taxes
  • Classifications and exemptions
  • Payments in lieu of taxes

We also can handle any type of federal tax matter, including disputes in the following areas:

  • Listed transactions and other IRS initiatives
  • Valuation matters, including difficult to value assets and closely held companies
  • Claims for domestic or foreign tax credits, including employee retention credits, renewable energy credits, and research and development credits
  • Complex partnership issues
  • Employee classification issues
  • SECA and employment tax obligations
  • Transfer pricing matters
  • Substantiation of claimed losses
  • Resolution of IRS penalties

Our team is comprised of two former IRS special trial attorneys and other seasoned federal tax litigators who have collectively represented hundreds of clients before the U.S. Tax Court and have tried more than 50 tax cases to decision. Our knowledge of the tax code and IRS procedures allows us to help clients diagnose tax problems, resolve disputes, and implement processes to avoid future issues.

We have successfully argued hundreds of cases before state and federal courts at every level, including the Supreme Courts of Alabama and Tennessee. Our team frequently represents clients before numerous administrative tax tribunals and agencies, such as the United States Tax Court, the Alabama Tax Tribunal, the Tennessee Department of Revenue Administrative Hearing Office, the Tennessee Claims Commission, Mississippi Board of Tax Appeals, and state and local boards of equalization. We also assist our clients in matters pending directly with the Alabama, Mississippi and Tennessee Departments of Revenue, as well as county property tax assessors and other taxing authorities.