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Jonathan E. Strouse

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Jonathan E. Strouse

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 thousands of 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).

He has also represented a variety 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.

Education

  • University of Wisconsin Law School, J.D., cum laude
  • University of Wisconsin, BBA, Finance and Accounting, with distinction

Organizations

  • ABA Tax Section, Member Individual Tax and Family Taxation Committee
  • Illinois CPA Society, Taxation Practice and Procedures Committee

Admissions

  • U.S. Supreme Court
  • U.S. District Court for the Northern District of Illinois, Trial Bar
  • U.S. Tax Court
  • U.S. Court of Federal Claims
  • U.S. Court of Appeals for the Seventh Circuit
  • U.S. Court of Appeals for the Ninth Circuit
  • U.S. Court of Appeals for the Federal Circuit
  • All State Courts in Illinois
  • All State Courts in Wisconsin
  • U.S. District Court for the Eastern District of Wisconsin
  • U.S. District Court for the Western District of Wisconsin
  • U.S. District Court for the Central District of Illinois
  • U.S. District Court for the Southern District of Illinois

Awards & Honors

  • American College of Tax Counsel (ACTC)
  • Leading Lawyers (2014-2019)
  • Beta Alpha Psi, Honorary Accounting Fraternity
  • AV Preeminent® Peer Review Rating from Martindale-Hubbell
  • Illinois Super Lawyers magazine (2009, 2013-2019)
  • Illinois CPA Society, Distinguished Service Award, 2020

Speeches & Publications

Speaking Engagements

  • Hot Practice Tips for Dealing With Innocent Spouse Relief, Individual & Family Taxation Committee, San Francisco, October 4, 2019
  • Contingency Fees in Tax Matters, ABA Section of Taxation, Individual and Family Taxation, New Orleans, LA, January 18, 2019
  • Federal Tax Audits of Tribal Resources and How a Tribe Should Prepare for and Defend Such Audits, First Annual Taxation in Indian Country Conference, Las Vegas, NV, December 10, 2018
  • Why Does the IRS Need to See That? Survivial Tips for an IRS Audit and Site Visit, NAFOA Fall Finance & Tribal Economies Conference, Santa Ana, NM, October 2, 2018
  • Examinations Based on Information Reporting, Illinois Society of Enrolled Agents, Bolingbrook, IL, June 14, 2018
  • Hot Topics Regarding Compliance with Circular 230, Illinois Society of Enrolled Agents, Bolingbrook, IL, June 14, 2018
  • How the EA Should Respond to Common IRS Penalties, Illinois Society of Enrolled Agents, Bolingbrook, IL, June 14, 2018
  • Zealously Representing Your Clients in an IRS Examination: What Every Enrolled Agent Needs to Know, Illinois Society of Enrolled Agents, Bolingbrook, IL, June 14, 2018
  • Hot Practice Tips Relating to IRS Controversies, Tax Audits, Procedures, and Ethics, Loyola Law School, April 5, 2018 ​
  • Section 104(a)(2) and the Taxation of Damages Received Pursuant to a Settlement - ABA Tax 2018 Mid-year Meeting, February 2018
  • Hot Practice Tips Relating to IRS Controversies, Independent Accountants Association of Illinois – Chapter 16, November 9, 2017
  • Presentation to Turkish Residents, November 1, 2017
  • Hot Practice Tips Relating to IRS Controversies, Tri-Counties Chapter of the ILSEA, September 6, 2017
  • Hot Practice Tips Relating to IRS Controversies, Chicago South Chapter, ICPA, July 20, 2017
  • Hot Practice Tips Relating to IRS Controversies, DHJJ - St. Charles, IL, May 31, 2017
  • Hot Practice Tips Relating to IRS Controversies, Loyola Law School, Tax Audits, Procedures, and Ethics, April 6, 2017
  • Tax Examinations Based on Information Reporting, ABA Section of Taxation, January 20, 2017
  • U.S. Tax Presentation To Turkish Residents, Raffles, Istanbul, Turkey, January 17, 2017
  • Additional Practice Tips for Zealously Representing Your Clients Before the IRS (Part 2), Fox Valley Chapter, IL CPA Society, January 13, 2017
  • Practice Tips When Dealing with the IRS - Part 2, presented to an Israeli accounting firm, November 27, 2016
  • Various Practice Tips When Dealing with the IRS Including Reasonable Cause Issues, presented to an Israeli accounting firm, September 4, 2016
  • Hot Practice Tips Relating to IRS Controversies, Fox Valley Chapter, IL CPA Society, June 10, 2016
  • Hot Practice Tips Relating to IRS Controversies, Tax Audits, Procedures, and Ethics, Loyola Law School, March 31, 2016
  • Hot Practice Tips for Representing Fiduciaries of Trusts and Estates Before the IRS, Peoria County Bar Ass'n, January 30, 2016
  • Offshore and Domestic Voluntary Disclosures, Illinois CPA Society, November 19, 2015
  • Presentation to Turkish residents regarding U.S. tax issues, Istanbul, Turkey, October 26, 2015
  • IRS "Additions to Tax - What is in a name - Part II," ABA section of Taxation, September 18, 2015
  • Hot Practice Tips Relating to IRS Controversies, Loyola Law School, Tax Audits, Procedures, and Ethics, March 05, 2015
  • IRS "Additions to Tax - What is in a name," ABA Section of Taxation, January 30, 2015
  • 2014 Tax Practice and Procedures Conference, Illinois CPA Society, July 17, 2014
  • Hot Practice Tips Relating to IRS Tax Controversies, 8th Annual Trust & Estates CLE Event for Legal Professionals, Bolingbrook, Illinois, April 23, 2014
  • Hot Practice Tips for Representing an Individual Taxpayer before and during an IRS Examination, ABA Section of Taxation, September 21, 2013
  • Helpful Tips on How to Bring a Case to the Taxpayer Advocate and Recent Changes to IRS Collection Alternatives, ABA Section of Taxation, September 20, 2013
  • Tips for Representing Taxpayers Before the IRS, Northwestern University Law School LLM Tax Program, September 17, 2013
  • 2013 IRS Practice and Procedures Conference, Illinois CPA Society, July 18, 2013
  • Crossing Borders to Conduct Discovery in Tax Litigation - Tools, Strategies and Evolving Issues, ABA Section of Taxation, May 10, 2013
  • Creative Strategies for Raising Capital & Doing Business in the United States and Complying with U.S. Tax requirements, Tel Aviv, Israel, May 6, 2013; Jerusalem, Israel, May 7, 2013
  • Ethical Concerns in Preparing Witnesses in Tax Litigation, ABA Section of Taxation, January 25, 2013
  • Hot Practice Tips for Representing an Individual Before and During an IRS Examination, ABA Section of Taxation, January 25, 2013
  • 2012 IRS Practice and Procedures Conference, Illinois CPA Society, July 23-24, 2012
  • Trust, Tax and Estate Planning Forum, Opal Financial Group, IRS Global High Wealth Industry Group, March 2, 2012
  • Requests for Admissions in Federal Tax Litigation, Illinois CPA Society, Chicago Metro Chapter, ABA Section of Taxation, October 20, 2011
  • IRS Global High Wealth Industry Group: Compliance for High Wealth Individuals and Their Related Entities, Society of Trust and Estate Practitioners (STEP) Los Angeles, CA, October 4, 2011
  • Common Interest Agreements, ABA Section of Taxation, May 6, 2011
  • Tax Lien Issues, IICLE Annual Real Estate Short Course, March 15, 2011
  • Regulatory Deference in Light of Mayo Foundation v. United States, ALI-ABA Telephone Seminar/Audio Webcast, February 23, 2011
  • Federal Audits of Indian Tribal Governments and Gaming Facilities: What We Have Learned (Part Three), "IRS Audits of Tribal Governments and Casino Revenues", January 25, 2011
  • Federal Audits of Indian Tribal Governments and Gaming Facilities: What We Have Learned (Part One), January 11, 2011
  • The New and Existing World of 1099-MISC and Related Issues, The Knowledge Congress Live Webcast Series, December 16, 2010
  • Privilege Issues in Tribal Tax Audits and Tribal Tax Litigation, Annual Tax Conference of the National Intertribal Tax Alliance (NITA), October 20, 2010
  • Defending and Resolving IRS Tax Audits, Annual Tax Conference of the National Intertribal Tax Alliance (NITA), October 19, 2010
  • Tax, Financial and Business Law Ramifications of Shareholder Disputes, DuPage County Bar Association, June 11, 2010
  • Tax, Financial and Business Law Ramifications of Shareholder Disputes, Illinois CPA Society, Lake Zurich Chapter, April 29, 2010
  • Tax, Financial, and Business Law Ramifications of Shareholder Disputes, Illinois CPA Society - Chicago Metro Chapter, March 31, 2010
  • Tax, Financial and Business Law Ramifications of Shareholder Disputes, Illinois CPA Society, North Shore Chapter, October 12, 2009
  • Selective Discovery Issues in Civil Tax Litigation, Moderator, ABA Section of Taxation, July 18, 2008
  • Tax Controversies and Procedure, Members of the Florida Institute of Certified Public Accountants, June 15, 2007
  • 5th Amendment Claims in Civil Tax Litigation, Moderator, ABA Section of Taxation, January 19, 2007
  • Judicial Estoppel in Tax Cases, ABA Section of Taxation, September 16, 2005
  • International Discovery: How to Obtain Discovery for Your Clients Outside the United States, ABA Section of Taxation, September 12, 2003

    Mr. Strouse has acted as lead trial counsel in the United States Tax Court over the past several years on the following cases:

    • John E. Goetz & Shannon R. Goetz v. Commissioner: Docket No. 015815-19 (Settled prior to trial)

    • Omicron Tech, Inc. v. Commissioner: Docket No. 015128-19L (Trial not yet scheduled)

    • Jacob Guedalia v. Commissioner: Docket No. 9747-19 (Settled prior to trial)

    • William B. Kohn v. Commissioner: Docket No. 008630-19L (Trial not yet scheduled)

    • Brendan J. Hagarty v. Commissioner: Docket No. 8485-19 (Settled prior to trial)

    • Ayoade S. Akere and Olabisi Y. Akere v. Commissioner: Docket No. 6501-19 (Settled prior to trial)

    • Edward Tarbox and Ekaterina Tarbox v. Commissioner: Docket No. 002980-19 (Settled prior to trial)

    • Nancy Kaplan v. Commissioner: Docket No. 024774-18 (Settled prior to trial)

    • William Henry Leggett v. Commissioner: Docket No. 015117-18 (Settled prior to trial)

    • Jeanne M. Butler & David J. Ferreira v. Commissioner: Docket No. 022498-18 (Settled prior to trial)

    • Gregory Smith & Stacy A. Smith v. Commissioner: Docket No. 022289-18 (Settled prior to trial)

    • Alycia M. Verdeyen & John Lawrence Porter v. Commissioner: Docket No. 015572-18 (Trial not yet scheduled)

    • John Doe v. Commissioner: Docket No. 026249-17 (Trial not yet scheduled)

    • Roofing Solutions, LLC v. Commissioner: Docket No. 13301-18 L (Settled prior to trial)

    • Vadim & Marina Lubomirsky v. Commissioner: Docket No. 11148-18 (Settled prior to trial)

    • Howard & Phyllis Izenson v. Commissioner: Docket No. 8402-18 L (Settled prior to trial)

    • Mona v. Commissioner: Docket No. 6304-18 (Settled prior to trial)

    • Noam Shapira v. Commissioner: Docket No. 5590-18 (Settled prior to trial)

    • Brenda E. Rodriguez & Omar Robles v. Commissioner: Docket No. 23992-17 (Settled prior to trial)

    • Engage Networks, Inc. v. Commissioner: Docket No. 16921-17 L (Settled prior to trial)

    • Blue Lake Rancheria Economic Development Corporation v. Commissioner: Docket No. 16150-17 (Decision in favor of Taxpayer)

    • Mainstay Business Solutions v. Commissioner: Docket No. 16189-17 L (Decision in favor of Taxpayer)

    • Templin Partners L.P., Sheri Templin, Tax Matters Partner v. Commissioner: Docket No. 14219-17 (Settled prior to trial)

    • Seasons Medical Group of Michigan, P.C. v. Commissioner: Docket No. 11329-17 (Settled prior to trial) ​

    • Alex R. Largo v. Commissioner: Docket No. 9172-17 (Settled prior to trial)

    • Ralph Schwartz v. Commissioner: Docket No. 26833-16L (Settled prior to trial)

    ​• Phyllis Schwartz v. Commissioner: Docket No. 26831-16L (Settled prior to trial)

    • Anis Elahi & Seema Elahi v. Commissioner: Docket No. 20406-16 (Trial not yet scheduled)

    ​• Joseph Adulamy v. Commissioner: Docket No. 6606-16 (Settled prior to trial)

    • Hema's Kitchen, Inc. v. Commissioner: Docket No. 1738-16 (Settled prior to trial)

    • John & Jane Doe v. Commissioner: Docket No. 1908-16 (Settled prior to trial)

    • Estate of Elizabeth M. McLeod et al. v. Commissioner: Docket No. 11715-15 (Settled prior to trial)

    • Old Town Pizza of Schaumburg, Inc. v. Commissioner: Docket No. 594-15 (Settled prior to trial)

    • Paul M. Goldberg v. Commissioner: Docket No. 026556-14 (Settled prior to trial)

    • Amir Blich & Iris Blich v. Commissioner: Docket No. 009259-14 (Settled prior to trial)

    • Joseph P. Secunda v. Commissioner: Docket No. 003471-14 (Settled prior to trial)

    • Estate of Betty M. Daily, Deceased, Marilyne Edmondson, Executrix v. Commissioner: Docket No. 005725-13 (Settled prior to trial)

    • Estate of Betty M. Daily, Deceased, Donor, Marilyne Edmondson, Executrix v. Commissioner: Docket No. 005724-13 (Settled prior to trial)

    • Rene and Theresa Lopez-Guerreo v. Commissioner: Docket No. 021455-12L (Dismissed prior to trial)

    • Michael and Jennifer Puelo v. Commissioner: Docket No. 018996-12 (Settled prior to trial)

    • Lee Loudermilk v. Commissioner: Docket No. 12054-11 (Settled prior to trial)

    • John Doe v. Commissioner: Docket No. 012254-10L (Settled prior to trial)

    • John and Jane Doe v. Commissioner: Docket No. 012253-10L (Settled prior to trial)

    • Elizabeth Doucas v. Commissioner: Docket No. 012252-10L (Settled prior to trial)

    • Greg and Zena Smith v. Commissioner: Docket No. 20552-09L (Settled prior to trial)

    • Jane Doe v. Commissioner: Docket No. 7993-09L (Settled prior to trial)

    • John Doe v. Commissioner: Docket No. 7994-09L (Settled prior to trial)

    • Robert Perry v. Commissioner: Docket No. 22324-08L (Settled prior to trial)

    • Terri E. Fuhr v. Commissioner: Docket No. 8815-08 (Settled prior to trial)

    • Estate of Allan Shapiro, Deceased, Linda Shapiro, Executor v. Commissioner: Docket No. 7925-08 (Settled prior to trial)

    • Robert C. Pfahl, Jr. & Nancy L. Pfahl v. Commissioner: Docket No. 1743-07L (Settled prior to trial)

    • William A. & Diane Y. Morris v. Commissioner: Docket No. 051408-06 (Settled prior to trial)

    • Open Pantry Food Marts of Wisconsin, Inc. v. Commissioner: Docket No. 20217-06 (Settled prior to trial)

    • Estate of William Berenson, Deceased, Frieda Berenson, Executor v. Commissioner: Docket No. 20764-05 (Settled prior to trial)

    • Estate of Grace S. Jennings, Deceased, Hugh L. Myers, Executor: v. Commissioner: Docket No. 018411-05 (Settled prior to trial)

    • Terri Eleen Fuhr v. Commissioner: Docket No. 15822-05 (Settled post-trial)

    • John H. Perkins, Deceased, John H. Perkins, Jr. and Robert G. Perkins, Successors-in-Interest, et al. v. Commissioner: Docket No. 13153-05 (Settled prior to trial)

    • Estate of Doris F. Kahn, Deceased et al. v. Commissioner: Docket No. 12551-04 (Decided on summary judgment)

    • Carol C. Duncan v. Commissioner: Docket No. 13515-03 (Settled prior to trial)

    • J. Betram Moher v. Commissioner: 03474-99 (Settled prior to trial)

    Mr. Strouse has also represented taxpayers in the United States District Court, the United States Court of Federal Claims, and the United States Courts of Appeal over the past several years relating to the following federal tax refund cases:

    • Yoglackshan and Saroj Ahluwalia v. United States of America, Northern District of Illinois, Eastern Division, Docket No. 1:19-cv-00229 (Settled prior to trial)

    • Estate of Florence W. Kirsch, deceased, Roberta K. Feldman, administrator v. United States Of America, Western District of New York, Rochester Division, Docket No. 6:16-CV-06599 (2016) (resolved prior to trial)

    • John Doe, Inc. v. United States of America, Middle District of Florida, Tampa Division, Docket No. 8:15-CV 1659 (2015) (settled prior to trial)

    • John Doe v. United States of America, Northern District of Illinois, Eastern Division, Docket No. 00-CV 635 (2012) (settled subsequent to appeal)

    • John Doe v. United States of America, U.S. Court of Appeals for the Seventh Circuit, Docket No. 11-3500 (2012) (settled pre-oral argument)

    • Estate of Morton Liftin et. al., v. United States of America, United States Court of Federal Claims, Docket No. 1: 10-CV (2010); Published at 2011 WL 5395546 (Fed.Cl.) (Decided on cross-motions for Summary Judgment)

    • Estate of Morton Liftin et. al., v. United States, United States Court of Appeals for the Federal Circuit, Docket No. 2013-5103 (2013) (Decided June 10, 2014, 2-1 Opinion)

    • John Doe v. United States of America, United States Court of Federal Claims, Docket No. 11-908T (2011) (Settled prior to trial)

    • Blue Lake Rancheria and Blue Lake Rancheria Economic Development Corporation v. United States of America, United States Court of Appeals for the Ninth Circuit, Docket No. 10-15519 (2010) (Summary judgment entered for taxpayer)

    • Avri and Marla Horowitz v. United States of America, Southern District of New York, Docket No. 10-Civ-7978 (2010) (Settled prior to trial)

    • Jay Horowitz and Carolyn Stankovich v. United States of America, Eastern District of New York, Docket No. 2:10-CV-04845 (2010) (Settled prior to trial)

    • United States of America v. William P. Doucas, et al., Middle District of Florida, Tampa Division, Docket No. 8:10-CV-1998 (2010), (Settled prior to trial)

    • Vista Motors Inc., LLC v. United States of America, Northern District of Illinois, Eastern Division, Docket No. 1: 10-CV-0134 (2010) (Settled prior to trial)

    • Blue Lake Rancheria and Blue Lake Rancheria Economic Development Corporation v. United States of America: Northern District of California, San Francisco Division, Docket No. C-08-4206 (2008) (Summary Judgment entered for taxpayers as ordered by the U.S. Court of Appeals for the Ninth Circuit)

    • John Doe and Jane Doe v. United States of America, Eastern District of Wisconsin, Docket No. 2:05 CV 1282 (2005) (Post-trial proceeding settled)

    • Supreme Industrial Maintenance Corporation v. United States of America: Northern District of Illinois, Eastern Division, Docket No. 96-CV-2950 (1996) (Settled prior to trial)

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