Skip to main content

Massey & Gail

Menu

“…a highly regarded boutique noted for its expertise in handling commercial litigation, with particular strengths in healthcare, business torts and tax-related disputes.”
Chambers USA Client

Tax controversies are often the province of specialists, who handle nothing but disputes with the federal government, states, or local municipalities. Tax specialists seldom practice outside of their niche area, confining themselves to those matters – often missing the forests for the trees.

Massey & Gail recognizes that when litigating against or negotiating with tax authorities, the playing field is tilted against us. We bring our perspective borne from decades of broad, generalist practice to tax controversies and disputes – providing a holistic approach that marries persuasive advocacy with technical expertise. For this reason, clients – including Fortune 100 companies – have relied on us to represent them in such matters when tens of millions or even billions of dollars are at stake. Similarly, we have considerable experience in the trial and appellate courts, handling civil cases and class actions, in which the liability theories involve a significant tax component.

Representative Matters

The Coca-Cola Company

Represent The Coca-Cola Company in an ongoing $12 billion federal transfer pricing dispute, advising on appellate strategy following an adverse Tax Court ruling.

High-net-worth Individuals

Represented high-net-worth individuals in a residency tax dispute involving whether they were subject to Illinois state income tax despite residing in Florida; challenged a more than $3.6 million deficiency assessment before the Illinois Independent Tax Tribunal, resulting in withdrawal of the assessment.

Local Appliance Relators

Represented local appliance relators in a multimillion-dollar qui tam action in Illinois Court of Appeals against a national home improvement retailer involving alleged failures to collect and remit sales tax in connection with appliance installation services; defeated summary judgment and awaiting trial.

Fortune 10 Retail Company (Pennsylvania sales tax class action)

Representing a Fortune 10 retail company in a putative consumer class action in the U.S. District Court for the Western District of Pennsylvania involving allegations of improper collection of Pennsylvania sales tax; secured dismissal with prejudice of statutory and common-law claims.

Fortune 10 Retail Company (Maryland flag sale)

Represented a Fortune 10 retail company in Maryland appellate proceedings involving allegations of improper collection of sales tax on an American flag purchase; secured dismissal in the Circuit Court for Anne Arundel County.