Tax disputes can save or cost a business thousands or even millions of dollars over multiple years. When high stakes impacts are on the line, you need specialized expertise.

We combine sophisticated knowledge of tax policy and regulation with persuasive advocacy. Our close working relationships and reputation for integrity with federal, state, and local taxing authorities allows us to develop innovative solutions that align with our clients’ business goals.  

We advise clients on favorable negotiation and settlement strategies, and—when appropriate—litigate a dispute to its ultimate outcome in federal and state courts. Our clients range from large multi-national corporations, Fortune 500 companies, high net worth individuals, to non-profit organizations.

Our team includes lawyers with extensive experience at all levels with the IRS, as well as state and local taxing authorities.

We represent clients at every stage of a tax dispute, including:

  • Exam
  • Appeals
  • Negotiation/Mediation/Arbitration
  • Discovery
  • Administrative Hearings
  • Federal and State Court Proceedings

Tax Controversy Client Results

Representative Matters
    • Negotiated multi-million dollar settlement with the IRS
    • Represented client in dispute with the IRS in front of U.S. tax court
    • Bresnan Communications, LLC v. Montana Department of Revenue, 13th Judicial Dist. Ct. No. DV-10-1312 (2011); we are representing a cable television company in a property tax dispute with the Montana Department of Revenue; Court has issued a ruling vacating the Department's retroactive assessments of our client's Montana properties
    • T-Mobile v. Utah State Tax Commission, 254 P.3d 752 (Utah 2011) (holding that goodwill is not subject to property tax in Utah)
    • Exxon Mobil Corp. v. Dept. of Revenue, 219 P.3d 128 (Wyo. 2009) (affirming ExxonMobil's position on proper point of valuation for natural gas)
    • Chambers v. Utah State Tax Commission, Case No. 050402915 (Utah Tax Court 2007) (holding an extraordinary 338(h)(10) gain to be non-business income)
    • Dept. of Revenue v. Exxon Mobil Corp., 162 P.3d 515 (Wyo. 2007) (ExxonMobil not liable for severance and ad valorem taxes on helium produced from federal leases)
    • Dept. of Revenue v. Exxon Mobil Corp., 150 P.3d 1216 (Wyo. 2007) (affirming ExxonMobil's position that royalties and production taxes are not direct costs of production under the proportionate profits valuation method for natural gas)
    • RME Petroleum Co. v. Wyoming Dept. of Revenue, 150 P.3d 673 (Wyo. 2007) (affirming taxpayers' position that royalties and production taxes are not direct costs of production under the proportionate profits valuation method for processed natural gas)
    • McFarlane v. Utah State Tax Commission, 134 P.3d 1116 (Utah 2006) (holding that resident S corporation shareholders are entitled to a credit for any tax paid in another state that is measured by income)
    • Homeland Development v. City of Bozeman, 18th Jud. Dist. Ct. No. DV-99-71 (2006); we represented property developers in challenge to impact fees imposed on new property development; case ended with a settlement under which the impact fees were stricken and our clients were awarded refunds in excess of $500,000.00
    • In 2005, Represented Arch Coal in a business income tax dispute with the Montana Department of Revenue; matter was resolved through negotiation prior to formal initiation of administrative review, and resulted in reduction in tax liability of over $1 million dollars
    • Continental Development v. Department of Revenue of the State of Montana, State Tax Appeals Board No. PT-2004-13 (2004-2005); we represented a property owner in a case of first impression addressing property taxation of apartments that were converted to condominiums; administrative proceedings resulted in reduction of assessed value of more than $3 million
    • Samson Resources Co. v. Abraxas Wamsutter LP, 117 Fed.Appx. 641 (10th Cir. 2004) (unpublished) (seller, not purchaser, of oil and gas properties subject to ad valorem tax on oil and gas production occurring before sale under state tax statutes and contract)
    • Board of County Commissioners for Sublette County v. Exxon Mobil Corp., 55 P.3d 714 (Wyo. 2002) (county lacks authority to appeal assessment by Department of Revenue prior to audit)
    • Amoco v. Utah State Tax Commission, Utah Tax Court Case No. 980406701 (Utah Tax Court 2001) (holding that an after-tax DCF must be used to value oil and gas reserves in Utah for property tax purposes)
    • Monson v. Utah State Tax Commission, Utah Tax Court Case No. 010402468 (Utah Tax Court 2001) (class action decision awarding sales tax refunds to over 120,000 taxpayers who were over-charged Utah sales tax on furnish and install sales of floor coverings)
    • Exxon Mobil Corp. v. Board of County Commissioners, Sublette County, 987 P.2d 158 (Wyo. 1999) (county judicially stopped from asserting it was not a party to settlement agreement concerning valuation of natural gas for tax purposes)
    • Helped lobby through the Utah Tax Court Act in 1996 which gave Utah an objective, de novo tax court
    • In 1995, Wyoming's governor appointed Holland & Hart attorney Larry Wolfe to serve on the Title 39 Task Force, which was charged with rewriting and recodifying the entire Wyoming Tax Code; this was a multi-year effort that resulted in the 1998 Wyoming Legislature adopting a completely revised tax code; Larry and Walter Eggers have worked on numerous legislative issues related to Wyoming's tax statutes, including mineral tax, property tax, and sales and use taxes; Larry is currently involved in various wind energy tax issues
    • Amax Magnesium Corp v. Utah State Tax Commission, 796 P.2d 1256 (Utah 1990) (holding a Utah statute unconstitutional because it favored locally-assessed properties over centrally-assessed properties)
    • Northwest Pipeline v. Property Tax Division of the Utah State Tax Commission, Utah State Tax Commission Case No. 85-0074 (Utah Tax Commission 1987) (holding that deferred federal income taxes constitute economic obsolescence for regulated utilities)

Tax Controversy Publications

  • "Recent Developments & Observations: Final Qualifying Income Regulations Under Code Sec. 7704(d)(1)(E) Were Worth the Wait," Journal of Passthrough Entities, May-June, 2017
  • "Recent Developments & Observations: More Than Meets The Eye? Recent Guidance on Tax Credits and Second Class of Stock," Journal of Passthrough Entities, September–October 2016
  • "Recent Developments & Observations: Do Rules of General Application Control in ESG Capital Partners and LTR 201605004," Journal of Passthrough Entities, May-June 2016
  • "Proposed Qualifying Income PTP Regulations," Journal of Passthrough Entities, September 2015
  • "Recent Developments Involving Energy and Taxes," Journal of Passthrough Entities, May-June 2015
  • "The Schizophrenic World of Code Sec. 1234A," Journal of Taxation and Financial Products, Wolters Kluwer, Volume 12, Issue 3, 2015

Tax Controversy Speaking Engagements and Events

  • "S Corporation Recent Developments," Federal Bar Tax Law Conference, March 3, 2017
  • "Section 708 Technical Terminations," Midyear Meeting, ABA Tax Section, January 20, 2017
  • "New Partnership Audit Provisions – Drafting Considerations," May Meeting, ABA Tax Section, May 6, 2016
  • "Partnership Tax Update," Holland & Hart 2015 Tax Conference , December 9, 2015
  • "2015 Holland & Hart Tax Conference," Denver, CO, 12/09/2015
  • "2014 Holland & Hart Tax Conference," Salt Lake City, UT
BTI's Law Firms with the Best Collaboration

One of nine firms nationwide named in 2017 by leading legal decision makers for “standout collaboration”

Tax Practitioner of the Year: Utah State Bar

Steve Young: Awarded the 2016 Tax Practitioner of the Year Award by the Tax Section of the Utah State Bar

17 Tax Best Lawyers® 2019

17 Tax attorneys recognized in 2019 Best Lawyers®: Litigation and Controversy - Tax;  Tax Law


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