Ellis Reemer represents clients in all aspects of sophisticated, challenging tax disputes, at the federal, state and local levels.
Ellis has more than 30 years of experience, first as a Senior Trial Attorney with the IRS Chief Counsel's office and then in private practice. His clients seek his advice and representation with respect to their most important and complex tax controversies and criminal tax matters.
In federal civil tax controversy matters, Ellis represents clients in IRS audits, in protests to the IRS Appeals Office, in tax litigation in the United States Tax Court, the United States District Court, the United States Court of Federal Claims and the United States Bankruptcy Court and in appeals to the United States Courts of Appeal.
In federal criminal tax matters, he represents clients who are targets, subjects and witnesses in criminal tax investigations being conducted by the IRS Criminal Investigation Division and by the Department of Justice.
International tax enforcement is a priority for the Department of Justice and the IRS. Ellis represents clients seeking to become compliant with US (as well as state) tax laws regarding international tax issues, including representing clients participating in Voluntary Disclosure Initiatives relating to previously undisclosed foreign financial accounts and in civil tax audits and criminal tax investigations related to these matters.
Where tax liabilities have been assessed but unpaid, Ellis represents clients before the IRS Collection Division and IRS Appeals in negotiating installment payment agreements and offers in compromise, in collection due process Hearings, and in resolving lien priority and levy disputes.
In state and local civil tax controversy matters, Ellis represents clients in tax disputes with state and local taxing jurisdictions throughout the US, with particular emphasis on tax controversies and tax litigations with the New York State Department of Taxation and Finance and the New York City Department of Finance. In those matters, he represents clients in audits involving income, franchise, sales and use taxes, as well as in audits involving residency and allocation issues. Ellis also represents clients in conciliation conferences with the Bureau of Conciliation and Mediation Services and in administrative hearings and appeals before the New York State Tax Appeals Tribunal and New York City Tax Appeals Tribunal. Ellis also represents clients in state and local tax collection matters including negotiating installment payment agreements and offers in compromise.
In state and local criminal tax matters, Ellis represents clients in criminal tax investigations being conducted by state and local taxing authorities, with an emphasis on investigations by the New York State Department of Taxation and Finance, the New York Attorney General and the New York District Attorney.
Ellis regularly represents accounting firms and their clients and is frequently consulted by other practitioners, among them transactional tax lawyers, bankruptcy lawyers, estate and gift tax attorneys, and matrimonial specialists.
