"Win/NO-LOSS" RECORD

• Pleadings
• Deficiency Actions
• Pretrial Negotiations
• Trial Preparation and Case Presentation
• Spousal Defenses
• Identity Theft/Fraudulent Returns
• Day-Trading Tax Advisory
• Delinquent Tax Return Preparation
• Collection and Due Process
• Offer in Compromise (OIC)
• Penalty Actions
• Motions Practice
• Post-trial Matters
• Rule 155 Computations
• 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")

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We function as a Federal Tax Law and Tax Advisory Group (NGO- non-governmental organization) and are affiliated with the nation's top Federal Tax Litigation and U.S. Tax Court trial practice research institution in the United States - The Tax Law Institute in Washington, D.C.. Situated in the U.S. Capitol and Honolulu, Hawai'i, and soon to open an office in London, U.K., the Tax Law Institute serves U.S.-based taxpayers with foreign assets as well as U.S. expatriates and overseas investors living in the United Kingdom and the European Union with taxable assets in the U.S. The Tax Law Institute's Litigation Services Group 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 also offer a Tax Advisory Service for investors engaged in day trading in the global securities market.

We are known for providing highly informative consultations, expert opinions, and written analysis to domestic and international clients on short notice, and for efficiently expediting settlements and litigation in the United States Tax Court.

Unlike other traditional Tax Law and Tax Advisory 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 some cases. Also, Michael Jerome Stuart, the John F. Dean Professor of Federal Tax Litigation and U.S. Tax Court Trial Practice, 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 group director Louis L.B. Carpenter (pictured), a corporate mergers and acquisitions expert and United States Tax Court Practitioner, admitted to practice in the U.S. Tax Court. He serves as Chief Tax Litigation Counsel. He is also a seasoned Certified Public Accountant and Certified Financial Planner. He has extensive experience as a tax litigator with an impressive record in the Court. Our Associate Tax Litigation Counsel - Jeffrey G. Thompson - is a United States Tax Court Practitioner, admitted to practice in U.S. Tax Court, and an IRS-approved enrolled agent, who developed a specialized practice in the Hollywood entertainment and film industry. He serves as lead Tax Litigation Counsel. 

Richard C. Cunha is a Family Law and Tax Attorney with 30 years of experience in civil trial practice and litigation. He is admitted to practice in the U.S. Tax Court.

The Tax Law Institute's Litigation Services 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 United States Department of the Treasury's Internal Revenue Service approved the Tax Law Institute 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 which he retired in 2014. He then joined the Tax Law Institute, where he lectured for 6 years as the Distinguished Judicial Speaker. 

Since then, our litigators have resolved tax matters in and before the IRS and U.S. Tax Court. 

Pictured is Tax Attorney Richard C. Cunha,  Admitted to Practice in the U.S. Tax Court