Federal Excise Tax Controversy Services 

Our professionals offer a complete range of services in the area of excise taxes, including the medical device, sporting goods, taxable fuel, air transportation, ozone-depleting chemical, oil spill, alternative fuel, heavy vehicle and foreign insurance taxes, and alcohol, biodiesel and alternative fuel incentives.
In addition, our services include providing advice and assistance regarding penalty standards and pursuing opportunities for penalty relief.

Our services cover, but are not limited to:

    Assistance With Excise Tax Responsibilities

  • We can work with you to help ensure compliance with federal excise tax requirements before a controversy begins. This includes assistance with excise tax positions taken on returns, registration with the IRS when applicable and obtaining correct documentation during the planning phases of your transactions.

    Examination Assistance

  • We can assist with all phases of the federal excise tax examination. We can advise on strategy, data accumulation and responses to Information Document Requests and other IRS requests. We can also assist with drafting requests for technical advice to the IRS Office of Chief Counsel, including reaching consensus on the relevant facts with the IRS and stating the applicable technical position.

    Appeals Assistance

  • During the Appeals phase, we can provide strategic consulting advice, prepare protests to Appeals, and represent clients during the Appeals process. This may include discussing potential errors in the examination team’s analysis of the relevant facts and applicable technical position.

    Assistance With Other IRS Controversy Issues

  • A number of IRS controversies are unique to excise tax, such as IRS registration-related issues. For example, there is a significant penalty for failing to be registered by the IRS as required. Our Excise Tax professionals can assist with all aspects of these controversies..


Ruth Hoffman, Director, Excise Tax practice, Washington National Tax