Matthew D Lerner

MATT LERNER, leader of the firm’s Tax Controversy practice, has more than 35 years of experience with tax-related matters, focusing on federal and state tax disputes at the administrative level and in litigation. He also has substantial experience in criminal tax controversies and complex civil litigation related to tax strategies.

Civil Tax Controversy and Litigation: Matt’s experience in federal civil tax controversy covers all stages of the Internal Revenue Service’s (IRS) administrative process and litigation in Tax Court, the Court of Federal Claims and the federal district courts. He often advises clients during the transaction planning stage and prior to audit to make sure their files are “audit-ready” and their defenses to possible challenges are well-documented. Likewise, he frequently works with clients on document retention policies and understanding their disclosure obligations. Once audits commence, he assists clients with IDR responses, witness interviews, developing a cohesive strategy with respect to their most challenging issues, and responding to Notices of Proposed Adjustments. He has broad experience at IRS Appeals, having favorably resolved dozens of issues, often in the face of conflicting IRS National Office positions.