Recent Publications by Townsend & Jones Attorneys

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Dallas

TOWNSEND & JONES, L.L.P.
Recent Publications

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Houston

Writings. Larry has written or co-authored the following:

·         Guide to Dealing With the IRS - published by Practitioners Publishing Co.

·         706/709 DeskBook - published by Practitioners Publishing Co.

·         Dealing With the IRS Collection Division - published by Little, Brown and Company

·         IRS Practice & Policy - Reviewer - published by Tax Management

·         Journal of Tax Practice and Procedure - Columnist and Advisory Board Member - published by CCH

Tax Controversy Update Blog. Larry is the Principal Contributor to the Firm's Tax Controversy Update Blog

Publications:

·         How to Find a Tax Attorney, Texas Lawyer

·         A Taxing Situation, Southwest Airlines Magazine - 1982

·         Handling an IRS Audit - Tips to Success, Dallas Times Herald - May 1986

·         Playing Hardball, Dallas Times Herald - September 1986

·         Defense Considerations in Criminal and Civil Tax Fraud Investigations by the IRS, Voice for The Defense - April 1987

·         Taxpayer's Rights, Family Solutions Quarterly - Winter 1989

·         IRS Takes Steps to Reduce Its Don't Mess With Us Image, quoted in article in Dallas Morning News - January 26, 1989

·         Dealing With Clients Who Have Not Filed Returns, IRS Practice Alert - October 1989

·         What to Do When a Client Has Not Filed a Return, WG&L Tax News - Spring 1990

·         Challenge the IRS, Dallas Law, Supplement to the Dallas Morning News - 1993

·         Can Your Client Afford to Litigate Against the IRS?, IRS Practice Alert - May 1990

·         What Starts Out as a Routine Audit May Transform Into a Fraud Inquiry, IRS Practice Alert - June 1990

·         Negotiating Options When Dealing With the Collection Division, IRS Practice Alert - July 1990

·         Winning Audits Through Communication, Preparation, and Presentation, Tax Management IRS Practice & Policy Bulletin - July 1992

·         The IRS Returns to Its Roots - Lifestyle Audits, Tax Management IRS Practice & Policy Bulletin - December 1995

·         Trust Fund Recovery Penalty: Can the IRS Recover From You?, Journal of Asset Protection - March/April 1996

·         IRS Allowable Expense Guidelines Impacting Taxpayers, Tax Management IRS Practice & Policy Bulletin - April 1996

·         Interpreting Consents to Extend the Statute of Limitations, Tax Notes - January 26, 1998

·         Taxing Question: How Can Businesses Avoid Audits?, Quoted in article in Dallas Business Journal - February 19, 1999

·         Love Thy Neighbor Before the IRS Does. CCH Journal of Tax Practice and Procedure - Apr.-May 1999

·         looking for An Innocent Spouse, CCH Journal of Tax Practice and Procedure - Aug.-Sept. 1999

·         How Modern will the IRS Be?,CCH Journal of Tax Practice and Procedure - Dec. 1999-Jan. 2000

·         Something Old, Something New for Practitioners to Keep in Mind, CCH Journal of Tax Practice and Procedure - Apr.-May 2000

·         The Statute of Limitations,CCH Journal of Tax Practice and Procedure - To Extend or Not to Extend - Aug.-Sept. 2000

·         Going to Appeals, CCH Journal of Tax Practice and Procedure - Apr.-May 2001

·         Planning the Transaction, CCH Journal of Tax Practice and Procedure - Apr.-May 2001

·         Challenging the IRS in Court, CCH Journal of Tax Practice and Procedure - June-July 2001

·         Preparing for the Audit, CCH Journal of Tax Practice and Procedure - Are You IRS Proof? - Aug.-Sept. 2001

·         Strange Words -.Audit and Examination, CCH Journal of Tax Practice and Procedure - Dec. 2000-Jan. 2001

·         The Other Elements of Success, CCH Journal of Tax Practice and Procedure - Apr.-May 2002

·         Protecting Yourself from the IRS, CCH Journal of Tax Practice and Procedure - Apr.-May 2002

·         Planning and Preparing for Clients Under Audit, CCH Journal of Tax Practice and Procedure - Dec. 2001-Jan. 2002

·         Let the Audits Begin, CCH Journal of Tax Practice and Procedure - National Research Program and Exam Re-Engineering Project Will Produce More Audits by the IRS, CCH Journal of Tax Practice and Procedure - Aug.-Sept. 2002

·         Fourth Down and Inches to Go - Do You Go For It?, CCH Journal of Tax Practice and Procedure - Dec.-Jan. 2003

·         Riddles Solved: Code Sec. 6672(d) for Those Who Don’t Read, CCH Journal of Tax Practice and Procedure - Apr.-May 2003

·         When Is Compensation Reasonable?, CCH Journal of Tax Practice and Procedure - Apr.-May 2003

·         Settlement Negotiations with an Appeals Officer, CCH Journal of Tax Practice and Procedure - June-July 2003

·         Customer Service - We All Want It, but Do We Get It?, CCH Journal of Tax Practice and Procedure - Aug.-Sept. 2003

·         Have You Been Audits?, CCH Journal of Tax Practice and Procedure - December 2003-January 2004

·         For Better, For Worse, or For Taxes?, CCH Journal of Tax Practice and Procedure - Feb.-Mar. 2004

·         Avoiding the Pitfalls of Circular 230, CCH Journal of Tax Practice and Procedure - Apr.-May 2004

·         IRS Exam Re-Engineering: What Should We Do As Practitioners?, CCH Journal of Tax Practice and Procedure - Aug.-Sept. 2004

·         The IRS Audit - Being Re-Engineered, CCH Journal of Tax Practice and Procedure - Oct.-Nov. 2004

·         When the Civil Audit Turns Criminal, CCH Journal of Tax Practice and Procedure - Dec. 2004-Jan. 2005

·         Where Does the IRS Get Information About Taxpayers?, CCH Journal of Tax Practice and Procedure - Apr.-May 2005

·         The Wolf Has False Teeth - Code Sec. 6721, CCH Journal of Tax Practice and Procedure - Feb.-Mar. 2006

·         25 Percent Omission Extends Statute of Limitations, CCH Journal of Tax Practice and Procedure - Apr.-May 2006

·         Ignoring IRS Notices - Can the Taxpayer Recover?, CCH Journal of Tax Practice and Procedure - Aug.-Sept. 2005

·         Who Do You Want for Clients?, CCH Journal of Tax Practice and Procedure - Dec. 2005-Jan. 2006

·         FIRPTA - Withholding on the Sale of Real Property, CCH Journal of Tax Practice and Procedure - Aug.-Sept. 2006

·         The Audit is Over - What Now?, CCH Journal of Tax Practice and Procedure - Dec. 2006-Jan. 2007

·         The Trust Fund Recovery Penalty - Are There Criminal Charges in Your Client’s Future?, CCH Journal of Tax Practice and Procedure - Dec. 2006-Jan. 2007

·         To Appeal or Not to Appeal, CCH Journal of Tax Practice and Procedure - Apr.-May 2007

·         Hello, I Am Your CP2000 Notice!, CCH Journal of Tax Practice and Procedure - Aug.-Sept. 2007

·         Schedule C - Business or Hobby? - Tax Practitioners Beware, CCH Journal of Tax Practice and Procedure - Dec. 2007-Jan. 2008

·         Fire the Client - Save the Practitioner, CCH Journal of Tax Practice and Procedure - Apr.-May 2008

·         Substantiate or Negotiate, CCH Journal of Tax Practice and Procedure - Aug.-Sept. 2008

·         Challenge the IRS - A “How to” Manual on Tax Controversies, CCH Journal of Tax Practice and Procedure - June-July 2008

·         Off to Court We Go, CCH Journal of Tax Practice and Procedure - Dec. 2008-Jan 2009

·         We’ve Come a Long Way - Where Do We Go Now? , CCH Journal of Tax Practice and Procedure- Apr.-May 2009

Speaking

Larry speaks to various groups on a variety of topics including how to Challenge the IRS in all areas of tax controversies. The following are some of the organizations to which Larry has spoken:

·         19th Annual Advanced Tax Law Course - Tax Section State Bar of Texas - Dallas

·         22nd Annual Advanced Tax Law Course - Tax Section State Bar of Texas - San Antonio

·         24th Annual Advanced Tax Law Course - Tax Section State Bar of Texas - Dallas

·         25th Annual Advanced Tax Law Course - Tax Section State Bar of Texas - Houston

·         26th Annual Advanced Tax Law Course - Tax Section State Bar of Texas - Dallas

·         27th Annual Advanced Tax Law Course - Tax Section State Bar of Texas - Dallas

·         ACPEN Satellite Broadcast - Tax Controversy Toolkit

·         Amarillo Area Estate Planning Council

·         American Business Women's Association - Cammaraderie Chapter - Dallas, Texas

·         American Society of Women Accountants - Dallas, Texas

·         American Society of Women Accountants - DFW Chapter

·         Association of CPAs in the IRS

·         Association of Women Entrepreneurs of Dallas, Inc.

·         Belew Averitt Network Meeting

·         Capital of Texas Enrolled Agents

·         CPA Club of North Dallas

·         CPA Forum of Dallas

·         Dallas Area Tax Administrators

·         Dallas Association of Legal Assistants

·         Dallas Bar Association - Tax Section

·         Dallas Citizen Police Academy Class #19 Graduation

·         Dallas CPA Society - 3rd Annual Free CPE Conference

·         DFW Chapter of Texas Society of Enrolled Agents - Arlington, Texas

·         El Paso Tax Institute

·         Fair Park Rotary Club - Dallas, Texas

·         First Wednesday Tax Forum - co-sponsored by Townsend & Jones

·         Financial Executives Institute - Dallas Chapter

·         Independent Small Business Association - Richardson, Texas

·         Lions Club - Dallas, Texas

·         National Association of Accountants - Dallas Chapter

·         National Association of Black Accountants - Dallas Chapter

·         National Tax Practice Institute - Las Vegas - July, 2003

·         North Dallas Bar Association

·         Oklahoma Society of CPAs - Tulsa, Oklahoma

·         Panhandle Tax Institute - Amarillo, Texas

·         Plano Area Enrolled Agents - Plano, Texas

·         Preston North Lions Club - Dallas, Texas

·         South Carolina Society of CPAs Tax Conference - Columbia, S.C.

·         Tax Alliance Conference - 1994, 1995, 1996, and 2002 to 2009

·         TAPA - Irving, Texas

·         Tax and Business Forum - Monthly meeting for CPAs and Enrolled Agents sponsored by Larry Jones and Townsend & Jones, LLP. - Dallas

·         Tax Controversy College - sponsored by the State Bar of Texas Tax Section - 2002

·         Texas A&M University Tax Practitioner Workshop - IRS Problem Resolution - 2000, 2003, 2004, 2005, 2006, and 2007 - Dallas, Houston, and San Antonio

·         Texas A&M University Tax Practitioner Workshop - How to Deal with the IRS - 2003 - Dallas, Houston, and San Antonio

·         Texas Society of Enrolled Agents 1997 TxSEA Convention - Houston, Texas

·         Texas Society of Enrolled Agents 2002 TxSEA Convention - Austin, Texas

·         Texas Society of Enrolled Agents 2006 TxSEA Convention - Waco, Texas

·         Texas Society of Enrolled Agents - Plano Chapter

·         The University of Texas School of Law 44th Annual Taxation Conference - Austin

·         The University of Texas School of Law 48th Annual Taxation Conference - Austin

·         The University of Texas School of Law 49th Annual Taxation Conference - Austin

·         The University of Texas School of Law 57th Annual Taxation Conference - Austin

·         The 43rd Texas Tech Tax Institute - Texas Tech College of Business - Lubbock

·         The 48th Texas Tech Tax Institute - Texas Tech College of Business - Lubbock

·         The 49th Texas Tech Tax Institute - Texas Tech College of Business - Lubbock

·         The 52nd Texas Tech Tax Institute - Texas Tech College of Business - Lubbock

·         TSCPAs Convention - Nashville, Tennessee

·         TSCPAs CPE Exposition ‘96 - Austin, Houston, and Arlington, Texas

·         TSCPAs Tax Practitioners Bootcamp - Austin, Texas

·         TSCPAs Dallas Chapter - Dallas, Texas

·         TSCPAs 1995 Estate Planning Conference - Austin, Texas

·         TSCPAs 1996 Texas Accounting & Business Show - Dallas, Texas

·         TSCPAs 1996 Advanced Estate Planning Conference

·         TSCPAs Corpus Christi Chapter Thirty-Eighth Annual Tax Seminar

·         TSCPAs Austin Chapter - Fourth Annual Fall CPE Expo

·         TSCPAs Austin Chapter 2000 Tax Conference

·         TSCPAs Austin Chapter 2001 Tax Conference

·         TSCPAs Austin Chapter 2002 Tax Conference

·         TSCPAs Austin Chapter 2009 Tax Conference

·         TSCPAs 42nd Annual Texas CPA Institute in Dallas, Houston, and San Antonio

·         TSCPAs 48th Annual Texas CPA Institute in Dallas and San Antonio, Texas

·         TSCPAs Forum on Doing Business With the IRS - Dallas, Texas

·         TSCPAs Rio Grand Valley Chapter

·         TSCPAs San Antonio Chapter - Hot Topics on Dealing with the IRS

·         TSCPAs Tax Controversy Extravaganza - Dallas, Texas

·         TSCPAs Texas CPA & Accounting Show - Dallas, Texas

·         University of Houston Law Foundation - Family Law Practice Seminar - Dallas & Houston - 2002 and 2003

·         Washington Society of CPAs - Bellevue, Washington

By Jack Townsend

Tax Crimes (Lexis-Nexis August 2009), a publication in the Lexis-Nexis Graduate Tax Series. Mr. Townsend co-authored this book with Larry Campagna (a leading Houston practitioner), Steve Johnson (professor at University of Nevada, Las Vegas) and Scott Schumacher (Assistant Professor, University of Washington School of Law). The book is designed for the student and, for teachers, there is a Teacher's Manual. The book is in hard copy format and may be purchased here.
Federal Tax Crimes, a self-published pdf text that started out many years ago for the University of Houston course on Tax Fraud and Money Laundering co-taught by Mr. Townsend at the University of Houston School of Law. The book morphed, substantially revised and shortened into the Lexis-Nexis Tax Crimes book noted above. Mr. Townsend updates the text periodically and it may be downloaded on the download page for this web site.
Tax Procedure, revised annually, is the book for a course on Tax Procedure taught by Mr. Townsend at the University of Houston School of Law. The book and related materials contain consists text discussion, relevant Code Sections, and certain cases designed to encourage students to think about the Tax Procedure process. The book is in electronic format (Adobe Acrobat pdf format). The book has a companion electronic file (also Adobe Acrobat) consisting of materials such as forms, publications, selected excerpts from congressional committee reports, and limited practice forms. The pdf version is updated every August for use in that year's Fall class. The book is downloadable on the download page for this web site.
Scoping the Conspiracy, 123 Tax Notes 1047 (May 25, 2009)
Tax Obstruction Crimes: Is Making the IRS’s Job Harder Enough?, 9 HOUS. BUS. & TAX L.J. 260 (2009).
Judge Posner's Opinion in Kikalos, 108 Tax Notes 593 (Aug. 1, 2005)
Collateral Estoppel in Civil Cases Following Criminal Convictions, 2005 TNT 4-28 (1/6/05).
Tax Treaty Interpretation, 55 Tax Lawyer 219 (Fall 2001).
Burden of Proof in Tax Cases: Valuations and Ranges, 93 Tax Notes 101 (2001), 2001 TNT 187-37 (2001).
Taxpayer Rights in Criminal Investigations, 90 Tax Notes 1842 (3/26/2001), 2001 TNT 52-63 (3/16/2001), 30 Tax Practice No. 1, p. 1 (April 2, 2001).
The Accountant's Role - and Risks - in Koveling, 2 Tax Practice & Procedure No. 4 p. 20 (Aug-Sept. 2000).
Natwest May Be the Law, But Is It Right?, published in each of the following Tax Analysts publications: 84 Tax Notes 772 (8/2/99); Tax Notes Int'l, July 26, 1999, p. 417; and Tax Notes Today 1999 TNT 147-80 (8/2/99)..
Reconciling Section 482 and the Nonrecognition Provisions, 50 Tax Lawyer 701 (Summer 1997)
Interpreting Consents to Extend the Statute of Limitations (co-authored with his partner, Larry Jones), 78 Tax Notes 459 (1/26/98)
Audits and Appeals: Developments, 54 N.Y.U. Institute on Federal Taxation, ch. 26 (1996);
Section 6103 and the Use of Third Party Tax Return Information in Tax Litigation, 46 Tax Lawyer 923 (Summer 1993) (primarily dealing with exploiting opportunities in transfer pricing disputes);
IRS Appeals and the Art of Persuasion, 3 IRS Practice & Policy Tax Management Bulletin (No. 2) 42 (November 13, 1992);
Procter & Gamble and Beyond, 44 The Tax Executive 17 (Jan.-Feb. 1992) (co-authored with a former partner) (the First Security/Aramco Advantage issue);
The Controversy Over Campbell; Slicing the Bologna Too Thin, 52 Tax Notes (No. 1) 83 (July 1, 1991) (the service partner issue that has gained much attention recently in the context of hedge and private equity funds compensation; Mr. Townsend's interest in this area is based on his having successfully handled the Government appeal in Diamond v. Commissioner, 492 F.2d 286 (7th Cir. 1974), which is the leading case in the area).