Tax Controversy & Litigation


Michael Best’s tax litigation team has an outstanding track record in resolving controversies related to federal and state taxes, primarily in the areas of corporate net income taxes, sales and use taxes, property taxes, and excise taxes. Our lawyers are valued for their strategic thinking and have extensive experience in administrative proceedings before the U.S. Internal Revenue Service and the Departments of Revenue in Wisconsin and other states.

In the event that clients’ tax controversies cannot be resolved with the applicable taxing authorities, we apply our collective experience to litigating these matters before state administrative agencies, and federal and state courts. These venues include, on an ongoing basis, the Wisconsin Tax Appeals Commission, the U.S. Tax Court, the U.S. Court of Federal Claims, Federal District Courts, and the Federal Circuit Courts of Appeal, as well as state appellate courts.


Our highly skilled tax litigators have won major cases in areas such as:

  • Federal income taxation of banks, insurance companies, and manufacturers
  • Multistate apportionment and allocation of income
  • Sales and use tax for retailers, manufacturers, telecommunications companies, and construction contractors
  • State income tax treatment of “safe harbor” leases entered into by public utilities
  • State income tax law regarding bad debt reserves by banks
  • Amortization of trademarks and other intellectual property
  • Insurance loss reserves resulting from transition from tax-exempt to taxable status
  • Property taxes and property valuation
back to top