Tax Controversy

Sonnenschein's tax controversy practice engages in all types of tax disputes and litigation. Our lawyers have handled tax controversies at all levels including state administrative tribunals, local administrative tribunals, state district and appellate courts, the United States Tax Court and federal appellate courts. We are experienced in representing clients from the initial audit level through appeals of litigated decisions, and all stages in between.

The national reputation of Sonnenschein's tax controversy practice is enhanced by the leadership positions our partners have held in a variety of professional associations including the Tax Section of the American Bar Association, the Chicago Bar Association, and the American College of Tax Counsel. One of our partners is an Adjunct Professor at Chicago-Kent College of Law. Our tax lawyers have written numerous articles for national publications and are frequently called upon to address a wide variety of business and professional associations, institutes and universities on various tax-related subjects.

Capabilities & Experience

Sonnenschein's experience in complex tax litigation matters includes the successful representation of McDonald's Corporation before the Tax Court involving the qualification of a transaction as a tax-free reorganization, the successful representation of taxpayers before the Tax Court involving the interpretation of the at-risk rules and the only successful representation during the last ten years of a taxpayer in a tax shelter leasing controversy. Sonnenschein was selected to represent all of the United States individuals who are "Names" in Lloyd's of London in an ongoing dispute with the IRS. We have also represented numerous other companies as well as several national law firms in Federal tax disputes commencing with advice at the audit stage, continuing through the administrative process and through litigation, including Merck, the Illinois Agricultural Association, Institutional Capital Corporation, M. Gottlieb Associates, Inc., Pepper Construction Company and Tyco Toys, Inc.

In addition to federal tax disputes, Sonnenschein actively represents major corporations in state and local tax disputes in Illinois. For example, Sonnenschein represented a consortium of major insurance companies (Allstate, Northwestern Mutual, Safeco, the Country Companies, Principal Mutual, New York Life and others) in challenging Illinois' proposed method of taxation of life insurance companies. Other major companies that Sonnenschein has represented in Illinois tax disputes include Northwest Airlines, Anheuser-Busch, SpaceCom, TransAmerica and The May Department Stores Company. Sonnenschein has also represented numerous major companies in tax disputes with the City of Chicago, including Sears, Citicorp, Yellow Cab, Michael Reese, and the Chas. Levy Transportation Co.

Sonnenschein's tax controversy capability extends beyond the borders of Illinois. Our tax lawyers have been selected to represent major businesses in tax disputes in other states, such as United Airlines (Wisconsin), Sumitomo Corporation (California), McDonnell Douglas Corporation (California), Brown Shoe Company (California) and Empire, Inc. (Pennsylvania).

Representative Clients