Tax Attorney Daniel W. Layton

It is well known that most tax cases settle. But, common sense dictates that settlement prospects are strongest when the opposing party is concerned about losing at trial. The IRS and federal prosecutors know about attorneys who talk a big game but have no history of holding them accountable in trial when push comes to shove. They know these attorneys will “always settle” if pushed hard enough. On the other hand, when the government knows it will be punished or publicly embarrassed if it acts unreasonably, the strength of our clients’ positions must be taken at full value.

Our trial experience includes high-stakes criminal and multi-million dollar trials involving complex legal questions and cases of first-impression.