Mr. Strouse concentrates his practice in the areas of litigation, federal tax litigation and federal tax controversies, including audits and appeals.
Mr. Strouse 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).
Mr. Strouse has 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 offshore voluntary disclosures including streamlined filings, FBAR issues, the trading safe harbour 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 corporate, partnership, individual, employment, and excise tax matters.
Mr. Strouse has effectively litigated tax cases against the federal government in the United States District Court, United States Court of Federal Claims, and the United States Tax Court.
Mr. Strouse has diverse experience in litigating federal tax issues including lien, levy, and other collection matters, valuation issues, independent contractor/employee issues, built-in gain issues on conversions of C corporations to S corporations, estate and gift tax issues, tax shelter cases, ESOP issues, excise and payroll tax issues and a wide variety of other complex tax matters.
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