Frank J. Jackson focuses his practice on federal and state tax controversies at every stage, including tax audits, administrative appeals and litigation. Over the last two decades, Frank has successfully represented domestic and multinational businesses, nonprofits and high-net-worth individuals and estates in disputes involving a wide variety of sophisticated tax matters.

At the examination and appeals stages of tax controversies, Frank achieves client goals through his substantive and procedural knowledge, strong communication and negotiation skills and innovative strategies. When litigation cannot be avoided or is in his client’s best interest, he provides effective representation in hearings and trials before the US Tax Court and US district courts. In cases where tax liabilities have been assessed but not paid, Frank represents clients before the Internal Revenue Services’ (IRS) Collection Division, including in the negotiation of installment agreements, offers in compromise and in resolving lien priority and levy disputes.

Frank has firsthand understanding of the priorities and processes of tax authorities. Early in his career, he served as a trial lawyer and National Tax Shelter Project lawyer for the IRS. In this capacity, he represented the agency in suits before the Tax Court and provided legal advice to revenue agents and officers.

Additionally, Frank handles sensitive tax matters involving fraud allegations and has extensive experience helping clients avoid penalties and criminal charges. To help US taxpayers ensure compliance with federal and state tax laws, he offers counsel on voluntary disclosure initiatives, including previously undisclosed foreign financial accounts, and regularly helps clients correct compliance errors.

Frank is also an avid writer and public speaker on tax law topics.

Michael J. Scarduzio focuses his practice on US and international tax matters, particularly civil and criminal tax litigation. From audit to litigation, he represents taxpayers in all phases of tax controversy, including novel issues of first impression such as financial hedging transactions using a captive insurer, US tax implications of a foreign master-feeder fund’s investment activities and matters arising under Internal Revenue Code (IRC) Sections 7216 and 7212(a).

Michael has experience handling a variety of complex tax issues, including partnership audit procedures under the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) and the Bipartisan Budget Act of 2015 (BBA), international tax and Report of Foreign Bank and Financial Accounts (FBAR) compliance, reportable transactions, transfer pricing, debt equity classifications, foreign tax credits and excise tax on reinsurers. He also advises on questions relating to the attorney-client and work product privileges arising in tax matters.

After law school, Michael served as a term law clerk for the Honorable Karen L. Hayes of the US District Court for the Western District of Louisiana. He also served as a judicial intern for the Honorable Dolores K. Sloviter of the US Court of Appeals for the Third Circuit during law school. And, while earning his LLM in Tax from NYU, he served as a legal extern for the Internal Revenue Service’s (IRS) Office of Chief Counsel and Large Business and International Division in New York.

Michael has contributed to several publications, including co-authoring articles in the Journal of Tax Practice & Procedure addressing potential abuse of CARES Act tax relief provisions, the BBA centralized partnership audit regulations, and the repeal of the TEFRA audit regime. He has also co-authored an article examining the United States’ role as a potential tax haven, published in The Champion.