Practice Areas

 

The firm provides legal services to individuals and businesses, and serves as legal resource for CPAs and other lawyers. Clients are located throughout Montana and the United States and abroad. The firm’s legal services include tax planning & implementation (wills, trusts, probate, incorporations, partnerships, LLCs, contracts, like-kind exchange agreements) and tax dispute resolution & litigation (income, estate, & gift tax appeals, collection disputes, tax discharges and lien subordinations).

 

• Tax planning and implementation involves:

 Estate planning [wills, revocable and irrevocable trusts, Crummey trusts, gifts, generation-skipping transfers, special- use elections, interest-free loans]; forming and using legal entities (partnerships, limited liability companies, joint ventures, C corporations, S corporations, nonprofit entities, trusts); minimizing the impact of taxation on individuals and various types of business entities; planning and defending special tax related transactions involving families, divorces, charitable gifts, tax-free exchanges, asset valuations, real estate, tax shelters, pensions, depreciation, insurance, and oil &  gas; structuring damage awards and settlements; and mitigating the burdens of paying tax debts.

 

• Tax dispute resolution involves:

  • Tax audit disputes (income, estate, gift taxes) before the Internal Revenue Service and/or state tax authorities.

  • Tax collection disputes (responsible officer liabilty, tax lien and priorities, bankruptcy discharges, wrongful levies, jeopardies, and summons enforcement) before the Internal Revenue Service and/or state tax authorities.

  • Tax deficiency proceedings before the United States Tax Court and the Montana District Courts.

  • Tax refund proceedings before the United States District courts.

  • Tax collection proceedings before the United States District courts, the Montana District Courts, and the U.S. Bankruptcy courts (wrongful levy, injunctive proceedings, quiet title, interpleaders and interventions).

  • Tax appeals before the Montana Supreme Court, the United States Courts of Appeals and the United States Supreme Court.