Guinevere M. Moore Attorney

First Admitted: 2008, Illinois

Professional Webpage: https://www.mooretaxlawgroup.com/attorney/moore-guinevere-m/

Bar/Professional Activity:

Member of the Board of Directors, Accounting and Financial Women's Alliance
Chicago Bar Association, Taxation Committee
American Bar Association, Section of Taxation, Chair of the Janet Spragens Pro Bono Award Committee
Chicago Bar Association
American Bar Association
Supreme Court of the United States
U.S. Tax Court
U.S. Court of Federal Claims
U.S. Court of Appeals Federal Circuit
U.S. Court of Appeals 11th Circuit
U.S. Court of Appeals 10th Circuit
U.S. Court of Appeals 9th Circuit
U.S. Court of Appeals 8th Circuit
U.S. Court of Appeals 7th Circuit
U.S. Court of Appeals 6th Circuit
U.S. Court of Appeals 3rd Circuit
U.S. Court of Appeals 1st Circuit
U.S. District Court Western District of Wisconsin
U.S. District Court Eastern District of Wisconsin
U.S. District Court Central District of Illinois
U.S. District Court Northern District of Illinois, Member of the Trial Bar
Supreme Court of Illinois
Immediate past Chair of the Standards of Practice Committee, American Bar Association Section of Taxation, 2022
Conference Chair, Women Who Count, 2020

Verdicts/Settlements (Case Results):

John Doe v. Trump, United States, and Jane Doe v. Trump, United States. Argued on behalf of anonymous plaintiff and putative class that CARES Act provision excluding US persons who are married to ITIN Holders from Economic Impact Payment is unconstitutional. Cases were rendered moot when Congress changed the law retroactively to award EIP payments to our clients as requested in the litigation., 2020
Katholos v. Commissioner, United States Tax Court Docket No. 19011-16. The IRS sought over $4 million in taxes and penalties from my client. I was engaged less than four months from when the case was set for trial. I settled case for $32,371 within 90 days of being engaged. , 2021
Thompson v. Commissioner of Internal Revenue, decision completely in favor of the taxpayer, holding taxpayer is entitled to deduct expenses for graduate school., 2019
Lamas v. Commissioner of Internal Revenue, decision in favor of the taxpayer, holding taxpayer met material participation requirements and was able to deduct losses as active losses., 2015
Alterman v. Commissioner, decision in favor of the taxpayer, holding no transferee liability under I.R.C. 6901, 2015

Representative Clients:

I represent a client who was assessed tax penalties in excess of $25 million, and I was able to get the IRS to abate over $20 million in administrative proceeds, 2022

Transactions:

Confidential IRS settlement, complete concession of just under 1 million in civil penalties., 2021

Pro bono/Community Service:

Represent taxpayers who cannot afford legal representation before IRS and United States Tax Court.
Prepared amicus brief for the Center for Taxpayer Rights in a petition for writ of certiorari to the United States Supreme Court., 2022

Honors/Awards:

Chambers High Net Worth Guide, USA, Tax: Private Client, 2022, Band 2
Volunteer of the Year, LadderUp
Public Interest Law Initiative Fellow, Domestic Violence Legal Clinic, Chicago
Nolan Fellowship, American Bar Association Section of Taxation
Volunteer Champion Award, Center for Economic Progress (CEP)
Rising Star, Illinois Super Lawyers Magazine
Chicago’s Notable Women Lawyers, Crain’s
Legal 500, Firms to Watch – U.S. Taxes: Contentious: Moore Tax Law Group LLC, 2022
America’s Top 100 Criminal Defense Attorneys for Illinois, 2022
International Tax Review — World Tax, 2022, Highly Regarded Practitioner for Tax Controversy, USA
Best Lawyers in America, 2022
Chambers High Net Worth Guide, USA, Tax: Private Client, 2022, Band 2 — The Moore Tax Law Group LLC

Educational Background:

DePaul University, B.A. With Highest Honors, 2003

Scholarly Lectures/Writings:

I am a regular contributor to Forbes IRS Watch , Contributor, IRS Tax Watch, Forbes, 2020
Guinevere Moore presented Nuts & Bolts of Tax Court Litigation: Trial and Stipulations of Fact, Witness Preparation and Impeachment, and the Rules of Evidence the American Bar Association Tax Section 2016 Midyear Meeting in Los Angeles, CA on January 30, 2016
Guinevere Moore presented Responding to IRS Penalties at the IRS Nationwide Tax Forum in Chicago, IL on July 13 and 14, 2016.
Guinevere Moore presented Ethical Issues in Representing Tax Professionals at the American Bar Association Section of Tax 2017 May Meeting on May 12, 2017.
Guinevere Moore presented National Institutes on Criminal Tax Fraud and Tax Controversy for the American Bar Association in Las Vegas, NV on December 6 – 8, 2017.
Guinevere Moore presented Preparing Witnesses to Testify and Current Law and Analysis at the American Bar Association 2018 Midyear Meeting in San Diego, CA, February 8 – 10, 2018.
Guinevere Moore presented D.C. Ethical Issues/Experts in Federal Tax Practice and Reasonable Reliance Defense and Work Product Protection at the Federal Bar Association 42nd Annual Tax Law Conference on March 9, 2018.
Guinevere Moore presented Statutes of Limitations on IRS Examinations and Ethical Issues Regarding Partnership Representatives at the American Bar Association Section of Taxation’s 2018 Fall Tax Meeting on October 5, 2018
Guinevere Moore presented Civil Tax Workshop: Responding to Summonses and What Everyone Needs to Know About Cryptocurrency: Part One: Tax Treatment of Cryptocurrency Transactions; Part Two: Enforcement When Cryptocurrency Transactions Go Wrong at the America Bar Association’s 35 Annual National Institute on Criminal Tax Fraud and 8th Annual National Institute on Tax Controversy in Las Vegas, NV on December 13 and 15, 2018.
Guinevere Moore presented Partnership Representatives: New IRS Final Regulations Under Section 6223 and Challenges for Pass-Through Entities in a Strafford webinar on January 30, 2019.
Guinevere Moore presented Updated Voluntary Disclosure Practices: Is this the Correct Path for your Noncompliant Client? At the Federal Bar Association Tax Law Conference in Washington, D.C. on March 8, 2019
Guinevere Moore presented Representing Taxpayers During Summons and Other IRS Interviews – Potted Plant v. Rambo at the ABA Section of Taxation in Washington, D.C. on May 10, 2019
Guinevere Moore presented Rock-Partnership Representative-Hardplace at the NYU Annual Tax Controversy Forum in New York, NY on June 20, 2019.
Guinevere Moore presented Rock-Partnership Representative-Hardplace at the NYU Annual Tax Controversy Forum in New York, NY on June 20, 2019.
Guinevere Moore presented Amending LLC and Partnership Agreements to Address Tax Reform and the Current IRS Audit Rules; Tax Law Considerations, Former Partner Contributions to Tax Liability, Push-Out Elections and More at the Strafford Webinar on June 25, 2019.
Guinevere Moore presented Real Estate 199A Aggregation and 469 Grouping Rules: Real Estate Professionals and Safe Harbor Election at the Strafford Webinar on July 2, 2019
Guinevere Moore presented The Obligation to Report Tax Related Misconduct at the New England IRS Representation Conference in a webcast on November 2, 2019
Guinevere Moore presented Seeing through the Haze, Navigating Legalized Cannabis in Illinois at the Chicago Bar Association in Chicago, IL on November 13, 2019.
Guinevere Moore presented It’s a Whole New World: Defending and Litigating Partnership Adjustments Under the Bi-Partisan Budget Act of 2015 at the American Bar Associations National Institute on Criminal Tax Fraud and Tax Controversy in Las Vegas, NV on December 12, 2019.
Guinevere Moore presented Ethical Issues Related to Limited Scope Engagements at the American Bar Association’s Section of Taxation Meeting in Boca Raton, FL on January 30 – February 1, 2020.
Guinevere Moore presented When is it time for an Engagement Checkup? at the Illinois CPA Society Summit, on August 25-26, 2020.
Guinevere Moore is Co-Chair of Women Who Count and presenting on ‘When is it time for an Engagement Checkup?’, held from October 28-30, 2020
Guinevere Moore presented on Tax Controversies at NYU’s 79th Institute on Federal Taxation, Monday, November 16, 2020
Guinevere Moore is speaking and presenting on ‘Best Practices for an IRS Exam’ at the National Association of Tax Professionals (NATP) TAXCON, which is taking place August 24–26, 2021
Guinevere Moore is speaking and presenting on ‘Best Practices for an IRS Exam’ at the Illinois CPA Society (ICPAS) SUMMIT21, on August 24, 2021
Guinevere Moore presented at The Freeman Law International Tax Symposium, November 18th & 19th, 2021
Guinevere Moore was a Moderator for “IRS Enforcement Trends” 2021 IRS Representation Conference (November 19, 2021).
Guinevere Moore and Zhanna Ziering presented on “The Attorney-Client Privilege and Work Product Protection in Tax Court – Developments and Best Practices (Ethics)”, 2021 American Bar Association 38th National Institute on Criminal Tax Fraud and 11th Annual National Institute on Tax Controversy, December 08 -10, 2021, Las Vegas.
Guinevere Moore was a Panelist for “Ethics and the Federal Tax Practice” FBA Tax Law Conference (March 3, 2022).
Guinevere Moore and Zhanna Ziering presented on “Foreign Financial Asset Reporting-Learn From Tax Attorneys” on a webinar hosted by CDH CPA (May 19, 2022).
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 Sixth Amendment guarantees the right to conflict-free counsel in a criminal case
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, 2019
Preparing Partnership Returns Under the BBA by Guinevere Moore and Elizabeth Yablonicky, Journal of Tax Practice and Procedure, February-March 2019
IRS Fumble: What to Do When a Tax Assessment’s Validity is Questionable by Guinevere Moore, ABA Tax Times, June 14, 2019
U.S. Citizens Living Abroad Should Consider Taking Advantage of New Relief Procedures by Guinevere Moore, Bloomberg Tax Daily Tax Report, Insight.
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.
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.
Is It Time for an Engagement Check-up? by Guinevere Moore, Journal of Tax Practice & Procedure, December 2019-January 2020
Retroactive Notice 2017-10 Is Problematic by Guinevere Moore and Elizabeth Yablonicky, Tax Notes Federal, April 6, 2020
The Incompetent Authority: Questions and Answers co-authored by Guinevere Moore, ABA Tax Times, August 25, 2020
The Incompetent Authority: Questions and Answers co-authored by Guinevere Moore, ABA Tax Times, March 12, 2021
Guinevere Moore is a regular tax contributor to the Forbes blog. Her posts cover a range of tax-related topics
Crypto Unicorn TaxBit Joins Forces With PayPal, Coinbase, FTX And More To Make Paying Bitcoin And NFT Taxes A Whole Lot Easier
Build Back Better Act Would Give IRS Agents More Power And Remove Important Taxpayer Protections – Retroactively. Passage Would Be A Titanic Mistake
Mad At The IRS? Blame Congress, Not The Commissioner
Cryptocurrency Front And Center In Revised IRS Voluntary Disclosure Practice
DOJ Names Experienced Cybercrime Prosecutor As First Crypto Enforcement Director

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