Jonathan E. Strouse concentrates his practice in the areas of litigation, federal tax litigation, and federal tax controversies, including audits and appeals.
Jonathan has represented numerous taxpayers across diverse boundaries including, trusts, estates, federally recognized Indian tribes and tribal members, municipal governments, foreign taxpayers, hedge funds, high-net-worth individuals, qualified ERISA plans including leveraged and non-leveraged ESOPs, accountants, tax-exempt entities, TEFRA partnerships, individuals involved in Derivium transactions, and S and C corporations (publicly traded corporations as well as privately held).
Mr. Strouse has extensive experience litigating cases on behalf of taxpayers against the Internal Revenue Service and United States of America in the U.S. Tax Court as well as the United States District Court. A list of his more recent cases can be viewed by clicking here.
He has also represented hundreds of taxpayers before the Internal Revenue Service on a wide variety of collection, examination, and appeal matters including listed transactions and other tax avoidance matters, foreign tax issues, “wealth squad” examinations, “Midco” and section 6901 transactions, valuation issues, domestic and foreign offshore voluntary disclosures including streamlined filings, FBAR issues, the trading safe harbor pursuant to Section 864(b), information reporting issues, penalty matters pursuant to Sections 6662 and 6707A, mediation proceedings pursuant to Rev. Proc. 2009-44, transfer tax issues, and various other trust, estate, corporate, partnership, individual, employment, and excise tax matters.
Prior to entering law school, Mr. Strouse practiced as a certified public accountant in public accounting for five years. Mr. Strouse regularly counsels other attorneys, certified public accountants, and enrolled agents throughout the United States and foreign countries regarding their representation of taxpayers before the Internal Revenue Service.
Speaking Engagements
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