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The R&D Tax Credit Best Practice Roundtable: February 18, 2026 at 12 PM ET.Learn More

MASSIE Services

Tax Controversy

Working with you as a trusted advisor.

Overview

Tax controversy work is part of our daily practice at MASSIE. We support Fortune 500 companies through every stage of an R&D tax credit examination.

Our team brings decades of experience working with the IRS, including:

  • CAP and large case examinations

  • Software and MITRE reviews

  • Examination support and protest drafting

  • Appeals and mediation support

  • Pre-trial strategy and counsel selection

  • Reverse audits

  • Kovel agreements with R&D litigation firms for staff support

Throughout the process, we guide your team and manage the details. As a result, you can stay focused on your core work.

Representation from Start to Finish

When an examination begins, MASSIE can work under a power of attorney and represent you from the opening conference through resolution.

We prepare your case, manage communication with the IRS, and keep the process moving forward.

Most matters resolve at the examination stage. This happens because we know how to present the technical work and documentation that support the credit.

During this phase, many teams also strengthen their documentation practices. The IRS often expects more than interview-based narratives. Our approach reflects what we see in current examination trends.

Privileged Support Through Kovel Agreements

In many matters, we work under a Kovel Agreement with outside counsel.

This structure allows MASSIE to provide technical and documentation support while maintaining attorney-client privilege. It also ensures close coordination between legal strategy and technical analysis.

Support Through Appeals

If a matter advances to appeals, MASSIE continues to advocate on your behalf.

Appeals and Mediation Experience

We have drafted numerous protests and supported appeals and post-appeals mediation nationwide.

We use a full range of settlement tools to pursue outcomes aligned with your goals. Our work reflects recurring themes in recent R&D tax credit cases, particularly those involving large case examinations and MITRE reviews.

Confidence in a Complex Process

R&D tax controversy involves technical detail, evolving standards, and significant stakes.

MASSIE helps your team navigate that complexity with clarity and confidence.

“My Company has been working with MASSIE R&D for the last 4 years. Given the technical nature to support our R&D tax credit calculations, we needed to use an external firm to assist us in maximizing our credits, both for US federal and the State of Georgia purposes. There are many accounting and specialty tax firms out there to choose from but making the decision to work working with MASSIE has been the right choice for us.”

Judd Schmid
Vice President – Corporate Controller
Vecima

"This is our second year with MASSIE We've worked with other firms in the past, but our first year with MASSIE made a tremendous change in the process improvement of how we gather R&D data and support to sustain in the audit. This year we added the use of Microsoft Teams, which in combination with MASSIE process made this year's R&D study even more efficient and smooth to the point that we were a few months before the schedule of completing the study."

Yana Brez
Sr. Manager Tax
Rehrig Pacific Company
2020 - 2025
Repeat Honoree
Financial Times
America's Fastest Growing Companies
2019 - 2025
Repeat Honoree
Inc. 5000
America's Fastest Growing Private Companies
National Sponsor
TEI
Tax Executives Institute

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MASSIE R&D Tax Credits