Philosophy of Our Tax Lawyers

It may be an understatement to say that tax laws are complex and forever changing. At WKPZ our tax lawyers understand the effects of complex tax rules, and offer practical counsel to achieve client understanding and goals. Our tax lawyers advise companies and individuals regarding both federal and state tax laws.  We regularly advise clients regarding the complexities of tax law without using unnecessary tax jargon so that every client has the ability to understand their tax picture and make informed decisions about solving their tax problems.   

We proactively assist our clients in actively managing their tax obligations.  Towards this end, we provide opportunities to partner with our clients when they make business decisions that have a tax component. 

Business Taxation

We provide tax advice and counsel for a wide range of clients, including business owners and tax exempt organizations. Areas of extensive experience include:

Planning related to buying or selling a business
Requirements for obtaining and maintaining tax exemption
Unrelated business income issues
Excess benefit transactions and related taxable expenditures
Addressing the proper reporting of transactions to the taxing agency
Representing clients before federal and state taxing agency exams
Representing clients in the United States Tax Court, U.S. District Courts, and state courts.

Personal Taxation

The Internal Revenue Code and state tax codes often influence individual decisions.  We work with individual clients to minimize their tax liability and manage their individual tax risk.  We take the time to understand the client’s tax goals and risk tolerance so that our advice further those goals and matches client tax risk tolerance.  

Also please see our Estate Planning and Probate Practice Area for more information about estate and gift tax planning.

Tax Audits

For more than 25 years our tax lawyers have represented clients before the Internal Revenue Service, state taxing agencies and the U.S. Department of Labor (DOL). We have pursued unresolved matters to the U.S. Tax Court, Circuit Courts of Appeal and other federal courts.

For example, we successfully sued the IRS when the IRS wrongfully levied our client’s funds for a non-existent tax liability. The court also awarded our client his attorneys’ fees. 

We have successfully represented numerous religious professionals in the U.S. Tax Court. Based on a search of minister tax cases, it appears that our lawyers are responsible for more reported minister court decisions than any other law firm in the country.

As part of our practice, we prepare and file applications for a private letter ruling on behalf of clients that want certainty on certain transactions.   When employers or individuals face tax audits or administrative hearings, our lawyers have the experience to properly address the DOL, IRS or state and local taxing authorities.

Tax laws change constantly, and our lawyers have a reputation for finding workable solutions to achieve client goals and business objectives.


Frank Sommerville
Marilyn S. Sims
Paul D. Strug