Larry A Campagna

Practice Areas

Family Office

Tax Controversy & Litigation

Tax

Criminal Tax Defense

Federal White Collar Criminal Defense

State and Local Tax Controversy & Planning

Paycheck Protection Program (PPP) Audits and Investigations

Employee Retention Tax Credit (ERC and ERTC)

Career

Larry 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 years, he has resolved thousands of civil and criminal litigation matters, many of which involved sophisticated and complex legal issues that established precedent in courts at the federal, state and local levels.

Highlights of Mr. Campagna’s career include: representing the first taxpayer to be awarded attorneys' fees by the Fifth Circuit Court of Appeals; serving as lead counsel in one of the largest project cases in the history of the United States Tax Court; and successfully defending one of the world's largest accounting firms in a tax malpractice case.

Mr. Campagna teaches a course in the law of Tax Crimes and Money Laundering as an Adjunct Professor at the University of Houston Law Center. Larry is also currently serving as President of the American College of Tax Counsel for the 2023 to 2024 year. The College is made up of approximately 700 of the top tax attorneys in the country, and the Fellows of the College devote their time to filing amicus briefs in important cases and taking on other projects to improve the tax system. He has also served the American Bar Association Section of Taxation as Chair of the Employment Taxes Committee; as Chair of the Subcommittee on IRS Investigations and Procedures of the Committee on Civil and Criminal Tax Penalties; and as Chair of a Task Force on Offshore Credit Card Cases of the Civil and Criminal Tax Penalties Committee.

Professional Memberships

American College of Tax Counsel: Fellow; Board of Regents, 2014-present, Vice President, 2022, Secretary- Treasurer, 2021, Chair, Nominations Committee, 2019 to 2021

American Bar Association, Section of Taxation: Administration, Vice-Chair, 2018-2021; Committee on Civil & Criminal Penalties, Chair, 2011-2013, Vice-Chair, 2009-2011; Liaison to Standards of Tax Practice, 2001-present; Task Force on Offshore Credit Card Cases, Chair, 2002-2008; Subcommittee on IRS Investigations & Procedures, Chair, 1992-1994; Task Force on Section 6672, Task Force on Attorneys Fee Awards; Committee on Employment Taxes, Chair, 1994-1996, Vice-Chair, 1992-1994; Chair of Subcommittee on Trust Fund Taxes, 1991-1992

College of the State Bar of Texas, 1990-present

State Bar Section of Taxation Committee for Liaison with the Comptroller of Public Accounts

CCH Journal of Tax Practice and Procedure: Advisory Board of Editors

Publications

The BBA Rules are Coming; Oil & Gas Financial Journal/November 2017

Tax Crimes: Cases & Materials, Casebook co-authored with John A. Townsend, Steve Johnson and Scott A. Schumacher 2d Edition published 2015 by Lexis-Nexis

The Eggshell Audit, Part II: Indicators of Fraud and IRS Fraud Development Procedures; Co-Authored with Caroline Ciraolo and Eric Green; CCH Journal Journal of Tax Practice & Procedure, March 2013

The Eggshell Audit, Part I: A Primer; Co-Authored with Caroline Ciraolo and Eric Green; CCH Journal Journal of Tax Practice & Procedure, July 2012

Tax Controversies and Tax Litigation Update: Enforcement Issues Regarding Undisclosed Interests in Offshore Financial Accounts; Co-Authored with Scott D. Michel and Charles R. Rettig; New York University Annual Institute on Federal Taxation 2012

But I Relied On My Accountant! The Scope of the Reasonable Cause Defense to Penalties; CCH Journal of Tax Practice & Procedure, August-September 2012

Tax Crimes: Cases & Materials; Casebook co-authored with John A. Townsend, Steve Johnson and Scott A. Schumacher, published 2008 by Lexis-Nexis

Deadline for Offshore Voluntary Compliance Initiative is April 15; Houston Business Journal Article, March 2003

Riddles Raised by Those Who Don't Read: Solving Purported Problems with the Right of Contribution Under I.R.C. § 6672(d); Journal of Tax Practice and Procedure, February – March 2003

Legal Surfing: Basics of the Internet for Lawyers; Texas Institute for Continuing Legal Education, 1998

Work Highlights

In Johnson v. Sawyer, we battled for 15 years against the IRS to obtain damages for the wrongful disclosure of Mr. Johnson's confidential tax information. The Government eventually paid Mr. Johnson the nation's largest settlement for wrongfully disclosing tax return information.

We served as lead counsel in one of the largest project cases in the history of the United States Tax Court, which involved over 2000 Petitioners and posed strategic and logistical challenges for both the taxpayers and the IRS. Our firm represented over 700 of the taxpayers and negotiated settlements on behalf of those taxpayers as well as generic settlements that could be applied to others with Hillcrest cases.

We represented the first taxpayer to be awarded attorneys' fees by the United States Court of Appeals for the Fifth Circuit.

Expert in these Jurisdictions

Bar Admissions:

Texas

Court Admissions:

United States Supreme Court

Supreme Court of Texas

United States Courts of Appeals for the Fifth, Ninth, Eleventh and Federal Circuits

United States Court of Federal Claims

United States Tax Court

United States District Courts for the Southern, Northern, Eastern, and Western Districts of Texas

Education