Tax Litigation and Controversy
On This Team
Michael Smalley heads the Firm’s Tax Litigation and Controversy Group and represents both businesses large and small as well as individuals in their disputes with the Internal Revenue Service and the Arizona Department of Revenue. The Litigation and Controversy Group has successfully represented clients in a wide array of disputes with taxing agencies, including issues with respect to business expense deductions, credits, tax penalties and liens, employment income and deductions, statutes of limitation and innocent spouse protection. The Litigation and Controversy Group has represented countless clients in all venues, including audits before the Internal Revenue Service and Arizona Department of Revenue, and in appeals from such audits, along with the United States Tax Court, State and District Courts. The Tax Litigation and Controversy Group is also adept at representing taxpayers in collection matters and reaching taxpayer friendly settlement terms with the applicable taxing agency.
Mr. Smalley previously represented the State of California Franchise Tax Board as lead technical counsel on a wide array of taxpayer disputes, and worked closely with the Internal Revenue Service on enforcement of federal tax laws within the State of California. This experience has allowed Mr. Smalley to attain a full understanding of not only the legal issues involved but also the administrative procedures of the taxing agencies, which can be just as important to the successful resolution of a tax controversy.
