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Hello all,

My interest in tax controversy work has recently been spiked by a former professor of mine. I’m a 0L currently working in Big 4 tax as a CPA.

I’m wondering if there are law firms in DC and/or NYC that specialize in tax controversy work/litigation (i.e. some or all of responding to IRS audit requests and working to reconcile tax positions taken vs. IRS adjustments, litigating in Tax Court, and litigating Tax Court decisions in a higher appellate court). If there are firms, or departments within larger firms, that have this as their primary focus, is it reasonable to assume someone with a CPA + Big 4 tax background could get a position like this by graduating median at a lower T14?

I also have a question regarding tax controversy. I am a 2L and have no tax background, other than the tax courses that I am currently taking and a member of our school's tax club. How steep of a battle is it for me to get a job dealing with tax controversies?

I’m going to let someone with a little more experience than me give better answers but, based on my experience:

(1) There is a decent number of firms with good controversy practices. Look up Chambers and Partners “tax controversy” rankings. Firms off the top of my head: Baker McKenzie, Jones Day (DC), Covington (DC), Caplin and Drysdale, Miller and Chevalier, Roberts and Holland, Steptoe and Johnson. Some are boutiques, some are BigLaw. Selectivity will largely be based on the firm with some (Covington) being more selective than others (Baker). There are probably more firms out there with groups as well. You may have to do tax controversy and tax transactional work your first few years before you can specialize, depending on the firm.

(2) Tax classes, your school’s tax group, and an educated/rational explanation of why you want tax/tax controversy should be just fine. My tax background was basically the same as yours (read: none) and I got plenty of offers. Very few people have a tax background or are interested coming out of 1L. I don’t think it will be an uphill battle at all (assuming good grades and interviewing skills).