Brian Harris helps clients resolve all matters of disputes with the IRS. He represents taxpayers in audits, appeals and tax litigation in federal courts, including the U.S. Tax Court and federal district courts.
Clients appreciate Brian’s knowledge of IRS practice and procedure, especially in formulating strategies for addressing their tax issues. Brian leverages his prior experience as a government attorney to craft a unique solution for each client.
Some of the issues that Brian has handled either in audits or litigation include:
- corporate and partnership basis and other issues
- FBAR and other international reporting penalties
- captive insurance and conservation easements
- trust fund recovery penalties and employment taxes
- the economic substance, sham transaction and step transaction doctrines
- fraudulent transfers and successor liability
- promoter and preparer penalties and injunctions
- summons enforcement
- refund litigation in district courts
- innocent spouse relief and many others.
He also regularly counsels clients on a variety of domestic and international tax planning issues, including U.S. citizens with undisclosed foreign financial assets.
Brian has also served as an expert witness in defense of malpractice claims against a tax professional.
He also represents clients before the Florida Department of Revenue.
Brian was previously a Trial Attorney with the Tax Division, U.S. Department of Justice where he represented the IRS and the United States in federal courts across the country. He litigated several of the government’s largest and most significant tax shelter cases involving hundreds of millions of dollars in taxes. This gives Brian a unique view into how the IRS and the DOJ evaluate, litigate and settle cases.
Brian has been board-certified in tax law by the Florida Bar since 2015.