Federal Tax Controversies
Representation before the IRS, Independent Office of Appeals, U.S. Tax Court, and U.S. Court of Appeals. Sound counsel for companies and individuals in tax disputes.
Learn MoreWhat We Do
Areas of Practice
Foreign Accounts Compliance
Bringing taxpayers into compliance with U.S. laws concerning foreign income, accounts, and entities. Hundreds of cases handled. National speaker and author.
Learn MoreEstate Planning & Expatriation
Trust drafting, beneficiary designations, Medicaid planning, marital agreements. Counseling Americans on expatriation from the United States.
Learn MoreHow It Works
Your Path to Resolution
A clear, confident process from first call to final resolution.
1
Initial Consultation
A gratis phone call to understand your situation, assess your needs, and determine how I can help. All communications are held in strict confidence.
2
Strategy & Analysis
I review your documents, research the applicable law, and develop a clear strategy tailored to your specific tax matter or planning goals.
3
Resolution & Results
I execute the strategy with precision, whether negotiating with the IRS, filing in Tax Court, or drafting your estate plan, and keep you informed at every step.
Stephen J. Dunn
Attorney at LawAbout the Attorney
Decades of Focused
Legal Experience
Throughout my career I have represented taxpayers in contested matters before the Internal Revenue Service, its Independent Office of Appeals, and, if necessary, in the U.S. Tax Court and the U.S. Court of Appeals. I provide sound counsel for companies as well as individuals in tax controversies, and obtain outstanding results.
I bring taxpayers into compliance with U.S. laws concerning foreign income, accounts, and entities. I have handled hundreds of foreign accounts compliance cases. I write and speak nationally on this practice.
"I am ethical in all matters, large or small."Full Biography
Client Testimonials
What Clients Say
Trusted by individuals and companies navigating complex tax matters.
Thought Leadership
Publications & Speaking
Publication
FBARs, Forms 8938, Income Tax, and Beneficial Ownership
Analysis of beneficial ownership concepts in reporting foreign financial assets to the U.S. government.
Speaking
ABA Presentation: "Expatriation From the United States"
Presented at the American Bar Association conference alongside Max P. Biedermann and Christina N. Romero, May 2025.
Analysis
Assessable vs. Nonassessable Penalties: Farhy v. Commissioner
Examination of IRS penalty assessment authority and its limits under the Internal Revenue Code.
National Authority
Foreign Accounts Compliance Blog
Ongoing authoritative commentary on FBAR penalties, streamlined procedures, and international information returns.
From the Blog
Latest Insights
Foreign Accounts
FBARs, Forms 8938, Income Tax, and Beneficial Ownership
Beneficial ownership and legal title are important concepts in the reporting of foreign financial assets and income therefrom.
Tax Controversies
Supreme Court Signals Reversal in Bittner
Whether the failure to timely file an FBAR constitutes one violation of the Bank Secrecy Act, or one violation per account.
Estate Planning
Required Minimum Distributions
Understanding the rules governing distributions from 401(k) plans, 403(b) annuities, and individual retirement accounts.
Common Questions
Frequently Asked Questions
Answers to the questions I hear most from prospective clients.
The initial consultation is a gratis phone call where I listen to your situation, ask clarifying questions, and provide an honest assessment of how I can help. All communications are held in strict confidence.
I represent taxpayers in contested matters before the IRS, its Independent Office of Appeals, the U.S. Tax Court, and the U.S. Court of Appeals. This includes audit defense, penalty abatement, collections disputes, and appeals.
Contact me immediately. There are several IRS programs, including Streamlined Compliance Procedures and the Delinquent FBAR Submission Procedure, that can bring you into compliance while minimizing penalties. I have handled hundreds of these cases.
Yes. I draft trusts and wills, fund trusts to avoid probate, review beneficiary designations, and handle Medicaid planning and marital agreements. I am expert in federal estate and gift taxation. I avoid estate planning gimmicks.
Yes. I counsel Americans on the legal, tax, and practical implications of expatriating. If it is in their best interests, I help them through the process. I recently presented on this topic at the American Bar Association conference.
Get in Touch
Considering Retaining Counsel?
Schedule a gratis initial consultation. All communications are held in strict confidence.