Charles Hodges

Jones  Day 

$ $$$

Peachtree Street Northeast 1420
Atlanta 30309 GA US

Charles E. (Chuck) Hodges focuses his practice on federal tax controversies and litigation and assists U.S. taxpayers facing tax disputes around the world. He has been involved in more than 125 cases against the IRS in the U.S. Tax Court; U.S. Court of Federal Claims; U.S. District Courts in Georgia, South Carolina, Florida, Texas, Delaware, Mississippi, and Arizona; and Courts of Appeals for the Fifth, Sixth, Ninth, and Eleventh Circuits.

Among his reported cases are Caracci v. Commissioner, 456 F.3d 444 (5th Cir. 2006) (intermediate sanctions/excise taxes) and Wright v. Commissioner, 809 F.3d 877 (6th Cir. 2016) (foreign currency contracts). By combining his tax law background with his master’s degree in economics, Chuck also advises clients on transfer pricing issues and the global taxation of intellectual property.

For more than 20 years, Chuck has handled every stage of a tax controversy from examination (including the CAP program) through court proceedings and all alternative dispute resolution options, including post-IRS Appeals mediation.

He represents Fortune 500 companies and their executives, privately held businesses, estates, high net worth individuals and their family offices, as well as exempt organizations.

Chuck is an international tax columnist for the Journal of Taxation and serves as chair of the Federal Bar Tax Section for Atlanta, secretary/treasurer of the Atlanta Bar Tax Section, and is a former chair of the Georgia Bar Tax Section. He is also a Fellow of the American College of Tax Counsel and a Fellow of the American College of Trusts & Estates Counsel (for tax controversies and litigation).

EDUCATION:

  • University of Florida (LL.M. in Taxation 1996);
  • Mercer University (J.D. 1995);
  • Clemson University (B.S. in Financial Management 1992)

BAR ADMISSIONS : Georgia and District of Columbia

EXPERIENCE:

  • Represented in the Sixth Circuit Court of Appeals a taxpayer in a matter involving the interpretation of a “foreign currency contract” under section 1256.  Sixth Circuit found in favor of taxpayer.
  • Represented in U.S. District Court a transportation company in a jury trial involving the IRS’ challenge of the per diem plan for reimbursing drivers for over-the-road travel expenses under section 62. The court issued directed verdict to the company at the conclusion of the trial with the IRS liable for attorneys’ fees.
  • Represented a corporate taxpayer in examination by the IRS of transfer pricing issues associated with sale of business assets to an Irish company.
  • Represented in the U.S. Tax Court an insurance company against an IRS challenge of tax implications of alleged failed tax-deferred “A” merger under section 368 that resulted in a full concession by the IRS.
  • Represented in the U.S. Tax Court a corporation in connection with an IRS challenge of deductibility of premium payments made to a captive insurance company under section 831. The IRS conceded the case shortly before trial.
  • Defended in U.S. District Court a taxpayer against the IRS’ motion to compel transactional tax attorney’s notes and related files. The IRS motion to compel was denied based on attorney-client privilege and work product protection.
  • Represented in the U.S. Tax Court a credit financing company in a TEFRA proceeding in connection with an IRS challenge of the company’s section 754 “step-up” in basis election and corresponding amortization deductions under sections 197, 754, & 743.
  • Represented in the U.S. Tax Court a large home builder against an IRS challenge of multiple conservation easements and other charitable contributions under section 170.

Cost

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Peachtree Street Northeast 1420
Atlanta 30309 GA US
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Broadway 42
New York 10006 NY US
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