Representation Of Professionals And Others In Niche Areas Of U.S. Tax Law
Beyond individual taxpayers, Moore Tax Law Group, LLC, represents professionals, employers and third parties who get caught up in IRS tax disputes and criminal investigations. With decades of collective experience, our tax attorneys provide focused legal counsel for a wide range of special tax situations.
We represent tax preparers, real estate professionals, property appraisers, estate executors, corporate executives, cryptocurrency investors and others in both civil and criminal tax matters. Based in Chicago, our U.S. tax law practice takes cases throughout the United States and worldwide.
Special Tax Situations We Handle
Our attorneys have the experience to handle your special circumstances. The following are some examples of situations we have handled, but is not an exhaustive list:
Representing tax professionals before the IRS: Moore Tax Law Group, LLC, represents certified public accountants (CPAs), tax return preparers and tax attorneys who are facing civil tax fraud or professional discipline sanctions by the IRS for allegedly aiding and abetting their clients in tax evasion, submitting false tax returns or false information returns, or improperly claiming deductions or tax credits.
We have advocated for return preparers and qualified appraisers before the IRS and the IRS Office of Professional Responsibility. As chair of the American Bar Association’s Standards of Tax Practices Committee, attorney Guinevere Moore designs and produces continuing legal education for attorneys and judges on tax ethics. She is uniquely qualified to address the criminal, civil and disciplinary aspects of these cases.
Real estate professionals and material participation examinations: The IRS frequently examines individuals who claim to be real estate professionals in connection with the level of participation and ability to take certain deductions for real estate activities. We have successfully defended these exams at the IRS examination and IRS appeals level and scored a victory in a material participation case in U.S. Tax Court.
Promoter penalty examinations: The IRS may assess myriad penalties against those who are purported tax shelter “promoters,” including penalties for the failure to register a tax shelter, the aiding and abetting of understatement of tax liability, the failure to maintain a list of advisees and the imposition of accuracy-related penalties. Our attorneys have experience defending these cases at the IRS examination and appeals level, and in court.
Cryptocurrency taxation: We counsel individuals and businesses who have received letters from the IRS regarding reporting of cryptocurrency transactions and amending tax returns for prior years. We also advise clients who want to proactively resolve tax obligations relating to cryptocurrency capital gains. Our founding attorney has presented at national forums on federal taxation of cryptocurrencies.
Estate and gift tax examinations: Our attorneys have successfully defended estate tax and gift tax exams at the IRS examination level. We have also been hired by estates to advise on preparing estate tax returns that will withstand an IRS examination. Personal representatives and executors face personal liability for the funds they pay out of an estate when the IRS is a creditor. We counsel those estate representatives at every stage, including filing returns, defending IRS audits and appeals, and Tax Court litigation.
Offshore compliance: Our firm has significant experience in representing individuals and estates in the IRS’ Offshore Voluntary Disclosure Program, Streamlined Filing Compliance Procedures, Streamlined Domestic Offshore Procedures, expatriation and delinquent filing procedures. We have guided our clients who have made errors in reporting foreign bank accounts or other foreign income to the IRS to select the program that is right for them or opt out and choose a different path if necessary. We are highly versed in individual reporting requirements related to foreign financial assets. In addition, we have represented individuals who have been unable to complete a voluntary disclosure due to a pending examination or other prohibition.
Tax issues faced by employers: The attorneys at Moore Tax Law Group, LLC, counsel businesses and corporate executives in disputes with the IRS involving employment taxes, executive compensations and employee plans. We have successfully resolved cases involving worker classification, penalties for failure to report and withhold payroll taxes, challenges to the deductibility of executive compensation as a reasonable and necessary expense and attempted disqualification of employee plans.
We understand that tax matters can be complicated. Discuss your unique circumstances with one of our experienced attorneys to find out how we can help you.
The Right Experience In Your Corner
Our boutique law firm concentrates exclusively in U.S. tax counsel and tax litigation, serving clients worldwide. To discuss your tax controversy or potential dispute with the IRS, please call 312-549-9990 or use our online contact form to arrange a consultation.