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Members of our Tax Controversy & Litigation practice filed comments last week on the proposed regulations published July 2, 2024, regarding the Employee Retention Credits. They argued that these proposed regulations exceed the IRS and Treasury authority. They also urged these bodies to abandon the current proposed regulations as they relate to the ERC, and to reconsider the appropriateness of the final regulations treating excessive ERC refunds as underpayments of tax, particularly in light of the Supreme Court's recent decision in Loper Bright Enterprises v. Raimondo.
Read the full letter below.
Senior CounselAsher Fried is a senior counsel in the Tax Controversy & Litigation Section of Chamberlain Hrdlicka in the Houston office.
Asher has significant experience representing clients in federal and state corporate and partnership ...
ShareholderCharles “Chuck” Rettig, a Shareholder at Chamberlain Hrdlicka in the Firm's Tax Controversy & Litigation practice and other Tax and Trust & Estate practices, served as Commissioner of the Internal Revenue Service (IRS) from ...
ShareholderJaime Vasquez is a tax attorney in San Antonio. Mr. Vasquez is the Managing Shareholder of Chamberlain's San Antonio Office.
Mr. Vasquez concentrates his practice on federal, state, and international transactional and tax ...
Senior AssociateJerrika Anderson is a member of both the Tax Controversy & Litigation Group and the Tax Group, based in the Atlanta office. As a former Senior Trial Attorney with the IRS Office of Chief Counsel, Jerrika specializes in tax, federal and ...
ShareholderJohn Hackney specializes in Federal and state tax controversy matters and tax litigation, including tax-related examinations and administrative appeals involving individuals, business enterprises, partnerships, limited ...
ShareholderKevin Sweeney is an experienced tax attorney and former federal prosecutor who specializes in defending clients in civil and criminal tax controversy and litigation matters. He focuses on high-stakes IRS audits, civil tax ...
Senior CounselKristen Lowther specializes in the area of tax controversy and tax planning. Her practice spans a wide array of tax matters, focusing primarily on helping individuals, partners/partnerships, and corporations to successfully ...
ShareholderLarry Campagna has an established reputation as an authoritative litigator in matters of business litigation, white-collar criminal defense, and particularly in federal, state and local tax controversies. For more than 45 ...
ShareholderLeo Unzeitig is a shareholder in Chamberlain Hrdlicka’s San Antonio office. He assists with a wide range of federal tax controversy and litigation matters at all stages before the Internal Revenue Service and federal courts. Leo ...
ShareholderPhilip Karter specializes in tax controversy and tax litigation matters. In his 40-year career, Mr. Karter has litigated Federal tax cases in the United States District Courts, the United States Tax Court and the United States Court ...
AssociateSam Kuzniewski is a member of both the Tax Controversy & Litigation Group and the Tax Group. Sam specializes in federal tax controversies and investigations, including sensitive issue examinations, administrative appeals, and ...
ShareholderTom Cullinan is a Shareholder in the Firm's Atlanta office. Tom joined the Firm from the IRS, where he served as the Counselor to the IRS Commissioner and then as the acting IRS Chief of Staff.
While at the IRS, Tom was a member of the ...
AssociateVictor J. Viser is an associate in Chamberlain Hrdlicka's San Antonio office. He focuses his practice on federal, state, and international tax planning and controversy matters.
Mr. Viser also has expertise on the Paycheck ...