Brent N. Bartlett

Brent N. Bartlett focuses his practice on tax controversy and litigation matters involving state, federal, and international authorities. He guides multinational corporations, complex partnerships, and high-net-worth individuals through all stages of tax disputes, including audits, administrative appeals, and litigation before the US Tax Court and other federal and state courts.

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• Represented a large multinational technology company in a Section 482 transfer pricing dispute regarding the arm’s-length value of a platform contribution transaction between cost-sharing participants*
• Resolved on favorable grounds proposed multibillion-dollar adjustments to a wide range of positions on tax returns across multiple years at the IRS Independent Office of Appeals for a publicly traded offshore drilling company*
• Resolved on favorable grounds a multimillion-dollar dispute for a large online marketplace facilitator involving sales and use tax determinations*
• Represented a large multinational technology company in multiple related Tax Court cases, including a cross motions for summary judgment concerning a more than $600 million adjustment to partnership basis for a German subsidiary, which ultimately resulted in the Tax Court issuing a precedential opinion (Continental Grand Limited Partnership v. Commissioner, 166 T.C. No. 3 (Mar. 2, 2026))*
• Resolved on favorable grounds several related multimillion-dollar disputes in the Tax Court concerning computation of certain partnership items*

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