Tax attorney Jonathan D. Mishkin has extensive experience in tax law, tax procedure, and winning tax cases. He has more than 17 years experience litigating all types of tax controversies, from individual tax liability and collection disputes to the largest, most complex corporate deficiency and refund litigation. Sometimes you cannot avoid litigating a tax controversy with the Internal Revenue Service or with the Oregon Department of Revenue. The dollar value of the issue may be too large for the taxpayer to settle, there may be disputes about the facts that cannot be resolved, or the parties may simply have different views of what the applicable law means. Mr. Mishkin can help you get the results you need.
Always sensitive to the cost of litigation, Mr. Mishkin endeavors to work with his clients to identify the issues that are likely to be critical to the litigation. He then focuses his efforts on those key issues, often beginning while the audit is still underway, so that he is in a position to push for the most favorable pre-trial settlement or to present the strongest case at trial. When IRS tax lawyer Mr. Mishkin takes your tax controversy to court as your tax attorney, the judge and the opposing party will be presented with the facts and the law in the most persuasive light.
Tax and Tax Controversy
Jonathan Mishkin specializes in Tax and Tax Controversy and advises and represents taxpayers before the IRS and the Oregon Department of Revenue. Specifically, he works tax audit administration throughout every stage and any court litigation that may result. Distinguishing his tax controversy practice, Mr. Mishkin comprehensively offers:
- Substantive expertise in diverse sophisticated tax issues
- Deep knowledge on tax procedure
- Extensive experience in IRS, Oregon Department of Revenue and U.S. Department of Justice correspondence
- Proven success in tax dispute resolution
For any type of business entity, estate, trust, individual and non-profit corporation, Mr. Mishkin can resolve substantive domestic and international income, estate and gift, employment, excise and tax-exempt entity tax issues. As a trusted business and trust tax lawyer, he fully assists you throughout all phases of the tax controversy process. His capabilities widely range from initiating audits and preparing protests, to negotiating settlements and litigating cases in U.S. Tax Courts and U.S. District Courts.
Concerned about cost and exposure? Mr. Mishkin avoids tax court litigation whenever possible. Rather, he counsels you while drawing on great familiarity with substantive, procedural and evidentiary rules. Through this approach, you acquire a coherent, consistent strategy for obtaining your desired outcome.
Further, Mr. Mishkin can help you respond to IRS inquiries at a tax audit’s earliest stages. By consistently approaching the audit and appeals, he vigilantly and creatively identifies potential settlement opportunities to maximize your leverage while preparing for litigation if necessary.
Whether you call on Mr. Mishkin when the tax controversy is starting or when it is continuing after your CPA or corporate counsel has failed, he will thoroughly explore every way to resolve your tax issues.
Areas of Expertise
- Wills / Trust planning
- Gifting strategies and techniques
- International estate planning, including offshore trusts
- Life insurance planning
- Charitable giving and entities
- Succession planning for business owners, including buy-sell agreements
- Estate administration and probate
- Estate and gift tax audit defense
- Trust and estate tax dispute litigation for any aspect
Closely Held Business Counsel
Mr. Mishkin counsels closely held businesses, whether owned by family or non-family shareholders, on varying legal and business issues. Witnessing the legal problems owners face every day, Mr. Mishkin designed his closely held business services to solve people problems. Thus, he counsels you to meet business goals based on your personal and professional ethics, style, approaches, risk tolerance and priorities. By getting to know you and your past experiences, he can help you facilitate effective problem solving.
Whether you make suits, sell software, build houses or log trees and are one patent away from an IP or one class action away from a disaster, you need a plan. Fully understanding family business, Mr. Mishkin develops this plan with you through the services:
- Asset-protection planning
- Management structure analysis
- Succession planning for owners
- Corporate and partnership control device development
- Minority-shareholder evaluation
- Management succession planning
- Ownership and management restructuring
Personal Wealth Management
- Estate planning
- Buy-sell agreement arrangement
- Tax planning and compliance
- Personal charitable foundation management
- Loans, letter of credit and finance lease transactions
- Venture capital and other private equity transactions
- Structured finance transactions
Mergers, Acquisitions and Dispositions
- Strategic acquisition expansion advisory
- Sell-out advisory
- Spin-off and spin-out advisory
- Transaction tax consequence analysis
- Financial adviser search and support