Larry Hoenig is a partner in the law firm's Tax practice and is located in the Silicon Valley office. His practice focuses on tax controversy work at the administrative and judicial levels. In the last ten years, his practice has focused primarily on property tax controversies ranging from $500,000 to over $100 million of taxes at issue. He has represented many different kinds of businesses including energy; real estate development and management; manufacturing; high tech (including manufacturers and users of computers, consumer electronics, network systems, telecommunications, data centers, and semi-conductor equipment); cable and software industries, as well as and many others. He has handled almost every kind of property tax issue that may arise, including valuation, situs, change of ownership, new construction, base year values, statutes of limitations, embedded software and other exemptions, tangibles vs. intangibles, trade level, audits, and numerous other factual, legal and procedural issues.

He is considered one of the leading property tax controversy attorneys in California and has handled cases in every California county. His controversy work has included matters at audit, local assessment appeals boards, county boards of supervisors, Superior Court and the Court of Appeals. In addition to this controversy work, Mr. Hoenig also gives property tax planning advice in connection with business transactions and counsels companies on how to reduce their assessed values before they get enrolled.

On the federal side, he has represented taxpayers in IRS audits, administrative appeals and tax litigation in the federal courts. His clients are generally corporate, partnership, trust or estate taxpayers involved in civil tax disputes with the IRS, often including many issues and several tax years. Some of the larger cases have involved international transfer pricing questions under section 482 of the Internal Revenue Code. He also often participates in “interested parties” meetings at the CA State Board of Equalization and often works with various governmental and taxpayer groups in Sacramento on proposed property tax legislation and regulations.