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.

In addition to his experience in managing tax controversies, Matt’s practice extends to numerous substantive areas of federal tax law. Among his recent representations are cases involving: transfer pricing; international inter-company transactions; debt/equity issues; the domestic production activities deduction under Section 199; the Section 41 research credit; worthless stock and abandonment losses; capital versus expense classifications; employee versus independent contractor classification; losses from trading in securities and commodities; inter-corporate transactions and consolidated returns; miscellaneous corporate fees and expenses; valuation questions; and placed-in-service date disputes. He has also handled cases involving tax shelters, accounting methods and promoter registration.

Matt has significant experience with many of the IRS alternative dispute resolution procedures, including Pre-Filing Agreements, Industry Issue Resolution, Technical Advice and Early Appeals Referral. He also has handled numerous Fast Track and Post-Appeals mediations.

Matt frequently speaks to business and tax groups on tax controversy and ethics topics and is nationally recognized for his practice. Chambers USA notes in its 2018 edition that he has “really good instincts, a good style in court and a wide range of experience,” and clients describe that he has “a great legal mind, but he also understands business and its interplay with the law, and can articulate that to non-tax people.”