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Federal and State Tax Controversy Practice

From the pre-audit planning stage through the final appeals of contested trial or administrative decisions, Thompson Coburn is experienced in all areas of tax controversy. We have advocated for thousands of our clients before the IRS and multiple state and local taxing authorities involving all levels of federal, state, local and foreign tax controversies, audits and appeals, competent authority matters, and trial and appellate litigation. We have been able to successfully resolve many of these tax controversies without resorting to litigation, but when administrative settlement is not possible, we have the capability and experience to see the issue through to the final appeal.
  • American Airlines, Inc.
  • Amazon.com, Inc.
  • AT&T Inc. (formerly SBC Communications)
  • Bally’s Total Fitness Corporation
  • The Boeing Company
  • Charter Communications, Inc.
  • Clayco, Inc.
  • Dierbergs Markets, Inc.
  • Edward Jones & Co.
  • Enterprise Rent-A-Car Company
  • Federal Signal Corporation
  • Ford Motor Credit Corporation
  • IBM Corporation
  • Insituform Technologies, Inc.
  • Laclede Gas, Inc.
  • L’Oreal USA
  • Lorillard Tobacco Company
  • Mallinckrodt, Inc.
  • Maritz Holdings Inc.
  • The McGraw-Hill Companies, Inc.
  • Peabody Energy Corporation
  • Scottrade, Inc.  
  • Stifel Nicolaus & Company
  • Tyco, Inc.
  • UniGroup, Inc.
  • Union Pacific Railroad Company
  • United Technologies, Inc.
  • U.S. Bank, N.A.
  • Washington University in St. Louis
  • Wells Fargo Bank, N.A.

  • Pending multimillion-dollar Missouri corporate income tax litigation involving application of “SRLY” rules to NOLs, business/ nonbusiness issues under the three-factor apportionment method and other issues for a Fortune 50 company.
  • Pending significant Missouri sales and use tax litigation involving the taxability of “load and leave software” for a Fortune 1000 company.
  • Pending multimillion-dollar Missouri sales and use tax litigation involving the application of an airline exemption.
  • Pending multimillion-dollar Missouri corporate income tax business/nonbusiness case involving complete disposition of a billion-dollar explosives business.
  • Successfully settled significant Missouri income tax business/nonbusiness issue for a Fortune 100 company; settled for less than anticipated costs of litigation.
  • Pending federal income tax controversy concerning deductibility of litigation settlement payments vs. treatment as redemption proceeds.
  • Successfully obtained a sales and use tax exemption for a large public foundation that became a nonprofit private foundation (settled at the courthouse steps).
  • Successfully obtained a multimillion-dollar Missouri corporate income tax refund for a Fortune 50 company (Supreme Court of Missouri).
  • Successfully obtained a multimillion-dollar Florida sales and use tax liability for a large privately held corporation (settled at the courthouse steps).
  • Successfully obtained an engineering sales and use tax exemption for large design/build contractor (Supreme Court of Missouri).