Donovan Legal PLLC represents businesses and high-net-worth individuals in tax controversy matters at the federal and state levels. The firm has handled multiple multi-million-dollar matters across the country, addressing income tax, partnership tax, and sales-and-use tax issues. The firm appears before the Internal Revenue Service, state departments of revenue, and administrative tribunals, and remains available to pursue judicial review where settlement at the agency level cannot be reached on acceptable terms.

Tax controversy is a substantial focus of the practice for a specific reason. Our attorney is a Certified Public Accountant in addition to being admitted to practice law in Florida and Massachusetts. That combination matters in controversy work. An audit or examination turns on whether the underlying transaction, return position, and supporting records hold up to scrutiny which is a question that lives at the intersection of substantive tax law, accounting method, and documentary evidence. A practitioner who reads the Code, the regulations, the partnership agreement, and the underlying entries on the return can engage the examining agent on every level on which the case actually moves. That capability is the firm’s core value proposition in this area.

FEDERAL TAX CONTROVERSY

The firm represents taxpayers before the Internal Revenue Service at every stage of the federal controversy process:

• Audits and examinations — representation during the field examination of returns, including correspondent communication, document production and privilege review, drafting of responses to information document requests, and negotiation with the examining revenue agent.
• Appeals — protests filed with the IRS Independent Office of Appeals, settlement negotiation, and resolution under hazards-of-litigation analysis.
• Post-Appeals matters — statutory notices of deficiency, Tax Court petitions, refund claim work, and coordination with trial counsel where Tax Court litigation becomes necessary.
• Partnership audits under the BBA centralized audit regime — partnership representative work, push-out elections, modification requests, and imputed-underpayment analysis.
• Penalty defense — reasonable-cause defenses under § 6664(c), substantial-authority and reasonable-basis analyses, and accuracy-related penalty disputes under § 6662.

STATE TAX CONTROVERSY

The firm represents taxpayers before state taxing authorities on income tax, partnership tax, and sales-and-use tax issues. State controversy work has its own procedural rhythm, and outcomes often depend as much on understanding the state’s administrative practice as on the substantive merits.

• State income tax audits and appeals — including residency disputes, allocation and apportionment issues, and pass-through entity matters.
• Sales-and-use tax audits and appeals — covering nexus, taxability of services, exemptions, marketplace facilitator issues, and assessment defense.
• Multistate matters — coordinated representation when a single set of facts produces parallel disputes in more than one jurisdiction.

PARTNERSHIP & REAL ESTATE TAX POSITIONS

The firm brings particular technical depth to controversy matters involving partnership and real estate tax positions. Real estate is the firm’s core asset class, and many of the issues that arise on examination including passive activity classification under § 469, partnership allocations under § 704(b), basis questions under § 704(d) and § 752, depreciation method and recovery period challenges, like-kind exchange disputes under § 1031, and self-employment tax exposure for limited partners and LLC members are issues the firm advises on in its planning and compliance work as well. Familiarity with the technical rules from the planning side translates directly into more efficient defense on the controversy side.

HOW THE FIRM WORKS WITH OTHER ADVISORS

Many controversy matters arrive at the firm through referral from the taxpayer’s existing CPA, accountant, or family-office advisor. The firm’s practice is structured to support, not displace, those relationships. The firm’s role in those engagements is typically scoped to the controversy itself: developing the legal defense, managing communications with the taxing authority, and preserving privilege where appropriate. The taxpayer’s ongoing CPA or compliance advisor remains in place and is included in the engagement as the facts and ethics rules require.

Where the taxpayer does not have a separate compliance advisor, the firm can also handle the underlying return work through its tax compliance practice.