Resolving Tax Matters Together

We take a collaborative approach to managing your tax controversies.

Purposeful Solutions

The rapidly-changing complexities of tax law present a consistent challenge to businesses and individuals. We will provide you with the professional advice, expert insights, and thorough research required to make an informed decision about your tax controversy.

Dedicated Service

Our team will help you identify the full-scope of your unique situation, understand all of your options for resolution, and proceed toward the most desirable outcome.

Tax Specialists

We focus specifically on tax controversy matters to ensure that you receive the highest-quality legal representation from experts who understand the practice better than any other firm.

Wagner Tax Law Blog

Let us help you understand your options for addressing your tax issues so that you can make an informed choice.

Treasury and Internal Revenue Service Crack Down on Related-Party Basis Shifting

In June of 2024, the Internal Revenue Service (IRS) issued guidance attempting to address the perceived inappropriate use of existing partnership rules related to certain related-party basis-shifting transactions. These basis-shifting transactions are intended to generate tax benefits without any meaningful economic substance. IRS exam teams have reported repeated instances of inappropriate basis-shifting practices by related-party […]

Internal Revenue Service Plans Dozens of Corporate Jet Audits

On February 21, 2024, the Internal Revenue Service (IRS) announced that it plans to begin dozens of audits on business aircraft involving personal use, contributing to the Inflation Reduction Act’s efforts to improve tax compliance for high-income individuals and businesses. These audits will focus on aircraft usage by large corporations, partnerships, and wealthy taxpayers, and […]

Two Easements Conserved But Not in Perpetuity

In February of 2020, the United States Tax Court issued a Memo, Railroad Holdings, LLC T.C. Memo. 2020-22 (U.S.T.C. Feb. 5, 2020), and an Order, Rock Creek Holdings, LLC, Tax Court Order, 2/10/2020. Both the Memo and the Order pertain to the conservation easement in dispute in the cases. In the first case, the Court […]