David T. Potts

David concentrates his practice on assisting clients with federal, state and local tax controversy matters at all stages before the Internal Revenue Service, State taxing authorities, and County Assessors, including appeals to state and federal courts.

David’s tax controversy practice is wide-ranging, reflecting significant experience with resolving IRS issues, including:

• Audits
• Collection cases
• Installment agreements
• Offers in compromise
• Penalty abatement
• Requests for collection due process hearings
• Trust Fund Recovery Penalty investigations and litigation
• Willful and non-willful voluntary disclosures of foreign financial assets
• Civil-penalty defenses under the Affordable Care Act (including §4980H employer-shared-responsibility assessments)
• Private letter ruling requests
• Innocent spouse claims
• Captive-insurance examinations
• Employee Retention Credit (ERC) claims and litigation
• § 1031exchanges
• IRS criminal investigations
• Tax lien discharge and subordination
• Claims for refund

David has guided numerous clients on state and local taxation (SALT) in numerous states, including sales and use taxes, withholding taxes, mixed beverage taxes, gross production taxes, multi-state taxation, and penalty/interest abatement.

David also assists and advises clients on challenging real and personal property valuations in administrative and judicial proceedings, including challenges to assessments, inappropriate valuations, and in pursuit of exemptions.

Although he has advised clients on a broad range of tax issues over the course of his career, David has experience advising companies on tax issues related to the operation of medical marijuana businesses in Oklahoma, development and operation of data centers, as well as the development of sustainable and renewable energy projects throughout the state.