Resolving Tax Controversies

Handling tax controversies is an area in which Ms. Forsberg worked for twenty years as a senior attorney in the Office of Chief Counsel for the U.S. Treasury. Currently in her practice, she represents clients, including individuals, corporations and trusts, in resolving their disputes with the Internal Revenue Service (IRS) and the Department of Revenue.

In tax controversy work, Ms. Forsberg represents clients at the administrative audit level, in the Appeals Division and in the courts, including the U.S. Tax Court. She has an accounting background, and understands complicated issues relating to accounting methods and issues (including those for trusts) and financial statements. Given that many of the cases she handled involved estates and trusts, she is familiar with business and real estate valuation issues, and technical arguments regarding estate tax law.

Ms. Forsberg has handled corporate issues including reasonable compensation, inventory issues, accumulated earnings and others. She has also worked on cases with many issues relating to individuals including proper deductions, bad debt losses, ownership of partnership interests, innocent spouse claims, penalties and others. The practices and procedures at the administrative levels of the IRS and revenue departments, and of the federal courts, including the U.S. Tax Court, are familiar to her. She has extensive knowledge of the Internal Revenue Code, and experience in interpreting the Code, rules and regulations on behalf of her clients.