Litigation, including but not limited to:

• United States Tax Court (pre-assessment and only prepayment forum);
• Tax Court petition and designation of place of trial;
• Automatic appeals office review if no appeals pre-petition;
• Responding to informal and formal discovery;
• Entering into stipulations;
• Drafting pre-trial memorandum;
• Assisting in trial;
• Analyzing burden of proof, burden of production and burden of persuasion, as well as presumptions thereto;
• Assisting in the briefing;
• Reviewing opinions and preparing for appeals;
• Court of Federal Claims (post-assessment and a refund forum);
• Establishing prerequisites (Flora) for refund suit;
• Filing a claim for refund;
• Arguing mitigation of prepayment rule;
• Arguing against and working with Department of Justice in Court of Federal Claims; and
• Making a qualified offer under 7430 for attorney fees and other costs.