Sullivan
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Sullivan represents clients in conflicts with the Internal Revenue Service and state tax authorities, and we are particularly recognized as a leader at resolving Massachusetts state tax controversies for both individuals and businesses.

We manage all stages of tax disputes, including audits, administrative appeals and litigation. When the stakes are large and the law is unclear, we obtain private rulings from the Internal Revenue Service and state tax authorities for our clients.

Recent Successes

Client Work

  • Partnership tax dispute before the U.S. Tax Court concerning the "at risk" rules and a single-member LLC
  • S corporation tax dispute before the U.S. Tax Court concerning debt basis and other issues
  • State income tax disputes of all sorts, including those concerning income apportionment, business purpose and economic substance
  • Disputes concerning state addback statutes and the deductibility of royalty and interest expenses
  • Qualification and defense of manufacturing corporations, research and development corporations and security corporations
  • State sales and use tax disputes, including manufacturer-vendor disputes, and disputes concerning use tax collection obligations
  • Domicile planning, audit defense and litigation for high-net-worth individuals (HNWI)
  • Disputes relating to administrative summonses issued by federal and state tax authorities, including third-party summonses
  • Discovery disputes related to attorney-client privilege and the work product doctrine
  • Disputes concerning the Massachusetts room occupancy excise, including the taxation of frequent guest programs and the nature of hotels subject to the excise
  • Disputes concerning the Massachusetts convention center surcharge as it applies to private charters and whale watch cruises
  • Responses to federal and state tax collection activities, including liens and levies
  • Voluntary disclosure agreements (VDAs) for non-filers
  • Advice concerning the filing of amended tax returns
  • Cooperation with our Government Investigations & White Collar Defense Group in potentially criminal tax matters
  • Pro bono representation in cutting-edge tax matters, such as the scope of medical expense deductions for a patient suffering from gender identity disorder
Viewpoints
All Viewpoints
How I Made Partner: 'Prioritize What Is Important to You, Do What Energizes You,' Says Sarah Wellings of Sullivan & Worcester
Sarah Wellings was profiled in the article "How I Made Partner: 'Prioritize What Is Important to You, Do What Energizes You,' Says Sarah Wellings of Sullivan & Worcester," published by Law.com [sub. req'd] as part of their “How I Made It Q&A Series." In the Q&A, Sarah addresses a range of topics related to her professional development as a lawyer, from her previous years as an associate at Sullivan to going in-house for 11 years, and her return to Sullivan and becoming a partner in January 2024. She reflects on the challenges faced along her career path and offers advice and insight about the keys to successful business development for herself and other lawyers. "Make sure you prioritize what is important to you and do what energizes you. This will help you avoid burn out and open doors that help advance your career in ways you never expect," she says.
Part 2: The Impact of Massachusetts Court Cases on State and Local Tax Policies
Richard Jones was featured in an episode of the SALTovation podcast titled "The Impact of Massachusetts Court Cases on State and Local Tax Policies," published on January 23, 2024. In the episode, part two of a two-part series, Rich continues the discussion with SALTovation on recent landmark cases and their implications on tax policies and practices. They discuss two important state and local tax cases: Akamai and Bass Holdings. They delve into the complexities of determining whether a company is selling software or services, and the taxation implications. They also explore the concept of unitary business and its impact on apportionment. In this episode, Rich provides valuable insights into the nuances of these cases and offers advice on navigating state and local tax issues. Topics discussed in this episode: The pronunciation and role of Akamai in the technology and tax world, exemplify the challenges in classifying software versus services within taxation. The significance of the unitary business principle in SALT litigation and its application in recent tax cases, specifically referenced in the 'Vas Holdings' debate. An explanation of how court decisions can overturn long-standing tax policies, offering a fresh perspective on statutory interpretations and SALT applications. Richard’s experiences in the courtroom, shed light on the strategies used in SALT litigation to secure favorable outcomes. The encouragement to question accepted tax policies and insights into the pendulum of taxpayer victories in recent SALT litigation. Listen to the episode »
Sullivan & Worcester Shortlisted for International Tax Review Awards
Boston, MA – Sullivan & Worcester has been shortlisted for the International Tax Review (ITR) Americas Tax Awards 2026 for Massachusetts Tax Firm of the Year. Nominees will be recognized and winners will be announced at the ITR Americas Tax Awards gala on October 29, 2026, in New York. The annual ITR Americas Tax Awards celebrate the most accomplished and distinguished tax and transfer pricing teams across 35 jurisdictions worldwide. In addition to recognizing excellence in tax litigation and advisory work, the program honors firms that are leading the way in tax technology innovation, in regulatory and compliance practices and in fostering diversity, equity and inclusion within the profession. “We are honored to be recognized among the leading tax practices in Massachusetts,” said Douglas Stransky, leader of Sullivan’s Tax practice group. “This nomination reflects our team’s commitment to delivering practical, sophisticated and client-focused solutions to complex tax challenges.” Sullivan’s Tax practice provides sophisticated counsel and legal advice to companies on a wide range of state, federal and international tax issues. The firm’s team provides creative solutions for the entire spectrum of tax-related legal issues, including tax planning for corporate reorganizations, representing clients in high-stakes tax disputes and advising companies on matters before the Internal Revenue Service and state tax authorities. For more information about awards and finalists, visit International Tax Review. About Sullivan Sullivan & Worcester (Sullivan) is a premier, AmLaw 200 international law firm with lawyers in Boston, London, New York, Tel Aviv and Washington, D.C. Sullivan’s clients, including Fortune 500 companies, leading financial services firms and asset managers, boards of directors, real estate companies, and emerging businesses, rely on Sullivan’s ability to navigate complex legal and operational landscapes, the impeccable judgment of its lawyers, and its commitment to best-in-class client service.
Sullivan & Worcester Attorneys Named to the 2026 Lawdragon 500 Leading Global Tax Lawyers Guide
Boston, MA – Sullivan & Worcester announced that David Nagle, Ameek Ashok Ponda and Richard Jones were selected for inclusion in the 2026 Lawdragon 500 Leading Global Tax Lawyers guide. The guide recognizes attorneys for exceptional work in handling tax aspects of transactional matters, complex tax disputes and litigation, and advising private wealth clients and family offices.  Dave is managing partner of Sullivan. He represents companies in tax disputes before the Massachusetts Department of Revenue and the Internal Revenue Service. He also advises companies and individuals in tax audits, administrative appeals, and litigation and state tax issues related to transactions. His recent professional honors include Best Lawyers’ Boston Litigation and Controversy - Tax Law Lawyer of the Year, Boston Magazine Top Lawyers in Tax and International Tax Review’s World Tax Guide. Ameek advises clients on domestic and international taxation matters, with a focus on mergers and acquisitions and real estate investment trusts (REITs). He is nationally recognized for his work in REIT conversions and cross-border matters across a broad range of property sectors. He has received numerous industry honors, including Forbes America's Best-In-State Tax Lawyers, Boston Magazine Top Lawyers in Tax Law and was ranked by Chambers USA as a Recognized Practitioner in Tax (2006-2026) and REITs: Tax (2013-2026). Rich handles state and local tax litigation for companies in a wide range of industries and transactional planning related to corporate, personal income and sales tax matters. A skilled litigator, he has a successful track record of recent landmark victories in tax cases before the Massachusetts Supreme Judicial Court. He has received numerous professional awards, including Massachusetts Lawyers Weekly Go To Tax Lawyer in 2026 and Boston Magazine Top Lawyers in Tax Law, and was ranked by Chambers USA in Tax. About Sullivan Sullivan & Worcester (Sullivan) is a premier international law firm with lawyers in Boston, London, New York, Tel Aviv and Washington, D.C. Sullivan’s clients, including Fortune 500 companies, leading financial services firms and asset managers, boards of directors, real estate companies, and emerging businesses, rely on Sullivan’s ability to navigate complex legal and operational landscapes, the impeccable judgment of its lawyers, and its commitment to best-in-class client service.

Tax Controversies & Litigation

Tax Controversies & Litigation

Tax Controversies & Litigation

Tax Controversies & Litigation