Guinevere Moore

Career

Ms. Moore has significant experience representing taxpayers in United States Tax Court. She has represented taxpayers in over thirty docketed cases in United States Tax Court, including most recently accomplishing a complete victory in favor of the taxpayer in Thompson v. Commissioner, Case No. 4165-19. Her tax court experience includes taking cases from initial examination all the way through trial and appeal, as well as negotiating settlements favorable to the taxpayer.

Ms. Moore routinely defends clients in Information Reporting examinations, and has successfully defended clients from penalties for the failure to file information returns or from disputed information returns including 3520, 5741, and FBAR. She recently published Information Return Penalties: How to Avoid or Contest Them in The Tax Advisor. Ms. Moore also routinely advises U.S. taxpayers from around the world regarding how to expatriate from the United States, and recently published U.S. Citizens Living Abroad Should Consider Taking Advantage of New Relief Procedures in Bloomberg Tax.

She is well-versed in all manner of IRS examinations and has defended taxpayers at IRS Examination level run by both Small Business / Self Employed, Large Business & International. She also defends taxpayers at IRS Appeals, and pursuing claims for refund.

In her role as Executive Director of U.S. Partnership Representative, Ms. Moore has become a go-to resource for partnerships seeking a partnership representative or assistance with revising partnership agreements to comply with the Bi-Partisan Budget Act of 2015.

Professional Memberships

American Bar Association

Chicago Bar Association

American Bar Association, Section of Taxation

Current Chair of the Standards of Practice Committee (Tax Ethics)

Chair of the Janet Spragens Pro Bono Award Committee

Chicago Bar Association, Taxation Committee

Accounting and Women’s Financial Alliance, Member of the Board of Directors

Publications

• DOJ Names Experienced Cybercrime Prosecutor As First Crypto Enforcement Director. Forbes.com

• Cryptocurrency Front And Center In Revised IRS Voluntary Disclosure Practice. Forbes.com

• Mad At The IRS? Blame Congress, Not The Commissioner. Forbes.com

• Build Back Better Act Would Give IRS Agents More Power And Remove Important Taxpayer Protections – Retroactively. Passage Would Be A Titanic Mistake. Read the article here. Forbes.com

• Crypto Unicorn TaxBit Joins Forces With PayPal, Coinbase, FTX And More To Make Paying Bitcoin And NFT Taxes A Whole Lot Easier. Forbes.com

• Guinevere Moore is a regular tax contributor to the Forbes blog. Her posts cover a range of tax-related topics.

• The Incompetent Authority: Questions and Answers co-authored by Guinevere Moore, ABA Tax Times, March 12, 2021.

• The Incompetent Authority: Questions and Answers co-authored by Guinevere Moore, ABA Tax Times, August 25, 2020.

• Retroactive Notice 2017-10 Is Problematic by Guinevere Moore and Elizabeth Yablonicky, Tax Notes Federal, April 6, 2020.

• Is It Time for an Engagement Check-up? by Guinevere Moore, Journal of Tax Practice & Procedure, December 2019-January 2020.

• Information Return Penalties: How to avoid or contest them, The Tax Advisor Guinevere Moore explores the vast Information Return Penalties the IRS has at its disposal and how taxpayers who are facing these penalties can avoid them or, if they are assessed, contest them.

• Virtual Currency Reality: The IRS Crack Down on Cryptocurrency, Journal of Tax Practice and Procedure Guinevere Moore examines the filing obligations for cryptocurrency holders, past IRS enforcement and IRS guidance, and next steps for IRS enforcement and cryptocurrency holders.

• U.S. Citizens Living Abroad Should Consider Taking Advantage of New Relief Procedures by Guinevere Moore, Bloomberg Tax Daily Tax Report, Insight. Guinevere Moore explores the benefits and guidelines of an IRS program announced on September 6, 2019 regarding new relief procedures available to taxpayers living outside the United States who wish to expatriate. For those who qualify, the terms of the program are quite generous. For those U.S. citizens who live outside the United States and are not in compliance with the IRS, an IRS examination may be on the horizon.

• IRS Fumble: What to Do When a Tax Assessment’s Validity is Questionable by Guinevere Moore, ABA Tax Times, June 14, 2019Back-to-back opinions released by the United States Tax Court on May 20 and May 21 of 2019 serve as compelling reminders that what we learned in kindergarten is true: the same rules really do apply to everyone. When the IRS does not follow required procedures, the Tax Court will not hesitate to invalidate an assessment and find for the petitioner.

• Preparing Partnership Returns Under the BBA by Guinevere Moore and Elizabeth Yablonicky, Journal of Tax Practice and Procedure, February-March 2019Tax return preparation is not for the faint of heart. Return preparers are expected to understand and advise their clients on a myriad of ever-changing tax issues, from what type of entity will provide the best tax advantages for a business to which deductions have been created, expanded, or eliminated under the tax code. Clients expect their tax professionals to have all the answers to their tax-related questions and to be able to help them keep taxes as low as legitimately possible.

• A Primer on Deducting Losses from Real Estate Activities for “the Rest of Us” by Elizabeth Yablonicky and Guinevere Moore, ABA Tax Times, February 22, 2019Your client has been reading the news about deducting real estate losses and comes to you wanting to know: why didn’t you tell me about all the deductions I could have been taking for my rental real estate losses? And can I pay a lower tax rate on my gains? You explain to your client that it is much harder to deduct real estate losses than the current news makes it seem. But your client, who owns several businesses, only one of which is real estate, wants to know – how do I start taking advantage of this deduction?

• The Sixth Amendment guarantees the right to conflict-free counsel in a criminal case. In addition to the obvious question of whether an attorney can represent co-defendants in a white-collar criminal case, there is the less obvious question of whether the attorney owes a professional duty to non-clients: the criminal defendant’s spouse and children. Whether an attorney owes a professional duty to a non-client, including the spouse of a client, depends on the state where the representation takes place.

• Reasonable-Reliance Defense and Work Product Protection by Guinevere Moore, ABA Tax Times, March 2018 In Estate of Marion Levine v. Commissioner, Docket No. 13370-13, the United States Tax Court issued a designated Order that granted the petitioner’s motion to limit the scope of an IRS subpoena duces tecum served on petitioner’s prior counsel. Attorneys from the Estate’s first law firm of record completed the estate planning during the decedent’s life, prepared and filed the estate tax return, defended an IRS examination, and, when the outcome of the examination wasn’t favorable to the Estate, filed a petition in Tax Court after the Notice of Deficiency was issued in 2013. The original law firm’s representation of the Estate continued through 2015, when new counsel entered an appearance on behalf of the Estate.

Practice Areas

Tax Litigation

Tax Controversy