"Win/NO-LOSS" RECORD

• Pleadings
• Deficiency Actions
• Pretrial Negotiations
• Trial Preparation and Case Presentation
• Spousal Defenses
• Collection and Due Process
• Penalty Actions
• Motions Practice
• Post-trial Matters
• Partnership Matters & Actions
• Civil Tax Fraud Defense in U.S. Tax Court
• Actions for Declaratory Relief
• Corporate Tax Actions
• Partnership Tax Litigation in U.S. Tax Court
• Taxation of International Transactions (International Tax)
• Appeals Research of Tax Court Cases Appealed to the Federal Circuit Court of Appeals
• Foreign Judiciary Advisory, Opinions and Declarations
• Tax-Exempt Qualifications (Initial or Continuing)
• Trust Fund Recovery Audits (Payroll Tax)
• Review for Section 6015(e) Relief ("Innocent Spouse")

We function as a Federal Tax Law Group (NGO- non-governmental organization) and are affiliated with the most sophisticated Federal Tax Research and U.S. Tax Court Litigation and Trial Practice law firm in the United States - The Tax Law Institute at Washington DC. Situated in Washington D.C., with an office in London U.K., the Tax Law Institute serves U.S.-based taxpayers as well as U.S. expatriates and overseas investors living in the United Kingdom and European Union with taxable assets in the U.S.. The Tax Law Institute aka as "TLI" is devoted exclusively to litigating tax controversies in and before the U.S. Tax Court. Our primary function is to prosecute the IRS and to resolve tax matters, where errors of determination give rise to low-, moderate- and high-liability cases docketed on the calendar of the Court.

We are known for our ability to provide highly-informative consultations, expert opinions and written analysis to domestic and international clients on short-notice, and for how we efficiently expedite settlements and litigation in the United States Tax Court, where we have long-established relationships and often saving our clients substantial fees. We are specialists in civil tax fraud, partnerships actions, and corporate matters that involve mergers and acquisitions. We also litigate qualification controversies for foundations and 501(c)(3) corporations. We have a fairly good record of obtaining favorable declaratory judgments and satisfactory results in litigation actions. Individual taxpayers, business and corporate owners along with partnerships are encouraged to contact us.

Unlike other traditional Tax Law Groups, our legal team works closely with the recognized Federal Tax Litigation Scholars. The Federal Tax Research Director, James H. Chapman, is the Joni D. Larson Professor of Federal Tax Research and Practice at the Tax Law Institute. Professor Chapman is a resident scholar of the Internal Revenue Code and U.S. Treasury Regulations. He is involved in all cases. Also, Michael Jerome Stuart, The John F. Dean Professor of Federal Tax Litigation and U.S. Tax Court Trial Practicce, who serves as the Tax Law Institute's veteran observer of U.S. Tax Court proceedings is consulted regularly, These individuals make invaluable contributions to each case. 

Our acclaimed Litigation Services Group is led by L.B. Carpenter (pictured), corporate mergers and acquisitions expert and United States Tax Court Practitioner, admitted to practice, U.S. Tax Court. He serves as Chief Tax Litigation Counsel. He also is a seasoned Certified Public Accountant and Certified Financial Planner. He has extensive experience as a tax litigator with an impressive record in the Court. 

A United States Tax Court Practitioner aka Tax Litigation Counsel is an United States Tax Court-approved tax professional and legal strategist, who has received litigation training and been examined by and admitted to practice in the United States Tax Court. They represent taxpayers - individuals, partnerships, corporations, estates and trusts - during legal proceedings held exclusively in U.S. Tax Court. Because of their highly specialized tax accounting skills, litigation training, and stringent IRS approval and practice requirements, USTCPs are often chosen by tax clients over tax attorneys to handle deficiency matters, civil fraud offenses and other complex tax controversies that migrate into U.S. Tax Court. 

Our Associate Tax Litigation Counsel - Jeff Thompson - is an United States Tax Court Practitioner, admitted to practice, U.S. Tax Court, and an IRS enrolled agent, who developed a specialized practice in the Hollywood entertainment industry.

Richard C. Cunha, Of Counsel, is a tax attorney with experience in civil and criminal tax trial practice.   

The Tax Law Institute was founded to serve tax clients throughout the U.S., Western Europe, the Middle East and Japan as well as those persons and entities with taxable assets under the jurisdiction of the United States Tax Court. It has a history of success in legal education, pro bono practice and U.S. Tax Court litigation. 

In 2012, the Tax Law Institute was approved by the United States Department of the Treasury's Internal Revenue Service as a provider of continuing professional education for IRS enrolled agents, attorneys and CPAs. 

Our history in U.S. Tax Court dates back to 1974 when a retired U.S. Tax Court judge, who helped shape our mission, entered tax litigation practice as Government counsel. He worked in both the international and domestic sectors of the Internal Revenue Service. In 1994, he was appointed to the bench from where he retired in 2014. He then joined the Tax Law Institute, where he lectured for 6 years as the Distinguished Judicial Speaker. 

In 2014, the Tax Law Institute partnered with the University of Alabama School of Law Graduate Tax Program and led the joint endeavor to train attorney-LLM. candidates in litigation and trial practice in the U.S. Tax Court. 

In 2018, the Tax Law Institute published the Guide to Admission and Practice in U.S. Tax Court, with contributions from a retired U.S. Tax court judge and an eminent Federal tax scholar and legal author et al,

In 2020, Attorney at Law Magazine published an article that featured the Tax Law Institute as the nation's only program to prepare federally-authorized tax professionals as non-attorney litigators engaged in exclusive trial practice in and before the U.S. Tax Court. 

In 2021, the Hawai'i Federal Tax Clinic aka Hawai'i Low Income Tax Clinic opened its doors to serve low-income taxpayers of the State of Hawai'i.The Clinic was founded and initially supported by the Tax Law Institute and a local tax preparation firm and sponsored by the Taxpayer Advocate Service of the IRS for TY 2021.  For the TY 2022, TY 2023, TY 2024 and TY 2025, the Clinic was funded by the Tax Law Institute and won litigation in U.S. Tax Court that saved low-income taxpayers over $300,000.00.

In 2024, after years of litigation and trial practice training that put qualified United States Tax Court Practitioners and attorneys before the Tax Court, the Tax Law Institute was approved to participate in the U.S. Tax Court Clinical, Student Practice and Calendar Call Program. The Tax Law Institute established its Tax Litigation Clinic to support the Pro Bono Program at the Hawai'i Federal Tax Clinic, formerly known as the Hawaii LITC Corp. To date, the HFTC has successfully litigated and won (or settled) all its cases with a 'no-loss' record. 

In 2025, the Tax Law Institute became engaged as a low-cost provider of litigation services for non-qualifying taxpayers, whose income exceeded IRS guidelines for pro bono services. Once again, the Tax Law Institute established and maintained a "win-win, no loss'" record. 

Pictured is our Chief Tax Litigation Counsel, L.B. Carpenter USTCP  CPA  CFP  Admitted to Practice, U.S. Tax Court