Our Tax Controversy Practice represents individuals, businesses, and nonprofit organizations in disputes with federal, state, and local tax authorities. We are seeking a driven, results-oriented Tax Controversy Director with 5+ years of dedicated tax controversy and leadership experience.
Position Overview:
As Tax Controversy Director, you will oversee a large, fast-moving inventory of active cases while directly representing clients in complex IRS examinations and litigation matters, including issues involving research credits, Section 174 capitalization, and Employee Retention Credit (ERC) claims. This is a high-impact leadership role for an experienced tax attorney ready to manage both a substantial caseload and a team of tax professionals.
Key Responsibilities:
- Oversee and manage a large, active case inventory (hundreds of concurrent matters), ensuring strict adherence to IRS deadlines and procedural requirements across the team.
- Represent clients directly in IRS audits, appeals, collections matters, and Tax Court litigation, including examinations involving research credits, Section 174 capitalization disputes, ERC claims, and other federal tax issues.
- Draft and review legal memoranda, IRS correspondence, and Tax Court petitions.
- Conduct and oversee legal research on the Internal Revenue Code, Treasury Regulations, case law, and IRS guidance.
- Direct the preparation and negotiation of Offers in Compromise, Installment Agreements, penalty abatement requests, and other tax resolutions.
- Oversee collection due process hearings, trust fund recovery penalty matters, and innocent spouse claims.
- Train, mentor, and manage a team of tax professionals, providing technical guidance and supporting their professional development.
- Interact with clients and government agencies in a professional and timely manner.
- Maintain oversight of case files, documentation, and legal records across the team's caseload.
Qualifications:
- J.D. from an accredited law school.
- Admitted to practice law and in good standing with at least one U.S. jurisdiction (Maryland preferred).
- 5+ years of dedicated tax controversy experience, including IRS audits, collections, and Tax Court litigation.
- REQUIRED: 2+ years of experience in a formal supervisory or management role.
- Proven ability to oversee a large, fast-moving case inventory (hundreds of active cases) while enforcing strict IRS deadlines.
- Demonstrated experience training and mentoring tax professionals to deliver successful resolutions.
- Strong legal research and writing skills.
- Excellent communication and interpersonal skills.
- Detail-oriented with strong organizational and time management abilities.
- LL.M. in Taxation or CPA license is a plus, but not required.
Benefits:
- Health, dental, and vision insurance
- 401(k)
- Paid time off
- Professional development / continuing education
