Working through the details


The U.S. Department of Justice engaged The Alta Group to present expert testimony for the IRS in its challenge to a large corporate taxpayer’s use of a lease-in/lease out (LILO) transaction. Deal documentation was voluminous and highly complex. The judge had to be coached through technical issues using demonstrative exhibits, charts, and graphs. With tens of millions of dollars at stake, the corporate taxpayer as the opposing party engaged a seeming army of attorneys, consultants, economists, and experts to support their position against the IRS.


Alta’s expert witnesses methodically reviewed thousands of pages of documents to reverse engineer the LILO transaction and expose the tax-orientated details using animated presentations and expert reports. During trial, Alta walked the Court through the transaction answering questions and leaving little room for opposing counsel to counter their testimony. After several months of study, the Court ruled in favor of the IRS based in large part on Alta’s expert testimony.

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