(847) 651-7881
From Dynamic Redmond, WA: A Full-Range IRS-Dispute Lawyer with National Stature and *Vast IRS-Dispute Experience* that Actually Includes . . . [scroll down, a lot]
IRS Audits, Administrative Disputes, and Litigation
IRS Criminal Tax Matters
IRS Income and Excise Tax Disputes
IRS Payroll Tax Disputes
IRS Estate and Gift Tax Disputes
IRS Corporate Tax Disputes
IRS Penalty Disputes
Disputes over Assessed and Statutory Interest
Disputes over Limitations Statutes, Including Mitigation, Equitable Tolling, Equitable Recoupment, Offset, and Informal Claims for Refund
Disputes over Alleged Tax Shelters and Lack of Economic Substance
Tax Disputes Involving Tax-Exempt Entities
Challenges to the Faulty Regulation under IRC s. 1061(c)(4)(A) Respecting the Taxation of Carried Interest Paid by Hedge Funds
Disputes over the Valuation of Tangible and Intangible Property, including Goodwill
Expert Tax Opinions for Purposes of ASC 740
Disputes over Alleged Prohibited Transactions
Disputes over Listed Transactions
Deductions for Worthless or Partially Worthless Debts
Change-in-Accounting-Method Disputes
Disputes over Charitable Contributions Made to Donor-Advised Funds
Disputes over Return-Preparer Penalties
Disputes over Proper Responses to IRS IDRs, Formal Document Requests, and Summonses (Issued During Audits)
Responses to IRS CP-Series Forms -- CP2000, CP162, etc. (Precursors to an Audit)
Removal and Enforcement of IRS Liens and Levies
Offers to Settle Large IRS Debts
Requests for Innocent-Spouse Relief
Disputes/Controversies Involving the U.S. Constitution (Not Limited to Tax Issues)
Challenges to Federal Rules and Regulations that Overreach (Not Limited to Tax Issues)
Federal Tax-Return Filing Obligations of Visa and Green-Card Holders
Foreign Bank Account/FBAR Non-Filings and Disputes
Amendment of Tax Returns to Include Form 8938, Respecting Specified Foreign Financial Assets (FATCA)
Amendment of Tax Returns to Include a Form 5471, Respecting Certain Interests in Certain Foreign Corporations
Amendment of Tax Returns to Include a Form 3520, Respecting Receipt of Certain Foreign Gifts and Transactions with Foreign Trusts
Disputes/Controversies with the U.S. Department of Justice
Disputes/Controversies with the U.S. Department of the Treasury
Disputes in Federal Courts, Including Appellate Courts
State and Local Tax Disputes and Litigation in IL, DC, and WI
Disputes with the Wisconsin Department of Natural Resources
Corporate Transparency Act (Final Regulations Issued by FinCEN on 9/29/22, effective 1/1/24)
Cryptocurrency Reporting, Including on Amended Returns
Appeals of Social Security/Medicare Premium Adjustments Under IRMAA.
Suspicious Activity Reports (SAR)/Anti-Money Laundering (AML).
A Tax Lawyer Who Has a Premier Legal Background, and a Washington Location.
About
Maybe you have a dispute with the IRS or expect one. Maybe you don’t welcome the news that the IRS was recently funded with an additional $80 billion to improve enforcement and taxpayer service, and that the IRS will hire 30,000 new employees during the next two years. Tom, with a singular background, can help.
Here are the three primary qualities that a taxpayer, expecting or involved in a dispute with the IRS or U.S. Department of Justice (DOJ) tax authorities, should seek out when hiring a tax-dispute lawyer:
A Long Record of First-Chair, Top-Tier Tax-Dispute Accomplishment — Preferably Forged in the Federal-Court “Crucible” and National in Scope.
Judgment Seasoned by 17 Years Representing the IRS in Court, and then Representing Blue-Chip Taxpayers for the Next 25 Years.
Integrity- and Expertise-Based Credibility with IRS and U.S. DOJ Tax Authorities, and with Federal Courts.
And if the tax dispute has possible criminal overtones, a fourth quality is critical as well: Criminal-Tax Experience, Preferably as a Federal Prosecutor.
* * *
A Premier, National Stature + A Washington State Location
Having represented the IRS during the first half of his tax career, and having represented a plethora of blue-chip corporate, non-profit, and individual taxpayers during the second half …
Having first-chaired in court a vast array of complex and mega-dollar civil federal tax cases from coast-to-coast for 40 years at the very highest reaches of the tax profession …
Having tried over 20 cases to a jury verdict, having argued 15 cases to federal courts of appeals (five), and having written and filed hundreds of briefs in court …
Having been a federal prosecutor, with criminal tax and non-tax jury-trial experience …
Having been promoted twice into ascending, competitive-service supervisory positions (GM-15) with the Tax Division of U.S. DOJ in DC, and having been a Tax partner or shareholder in two of the nation’s largest and most prestigious international law firms …
Having demonstrated a nimble intellect and thought leadership by publishing extensively in premier national tax and non-tax publications, including three authoritative commercial treatises, across four different decades (1980s, 2000s, 2010s, and 2020s) …
Having practiced for 18 years each in the “tax vortices” of DC and Chicago, first-chairing cases worth $3 to $4 billion — and now, since 2019, practicing federal tax law from Redmond/Bellevue, WA …
Having first-chaired $500 to $600 million of federal-court tax cases while practicing at his own solo law firm (started back in 2016) . . .
Having received over twenty coveted, formal awards from his lawyer peers in the “tax vortices” of DC and Illinois, across five different decades (i.e., 1980s, 1990s, 2000s, 2010s, and 2020s) … and
Holding a J.D. degree from a leading Big Ten, first-tier law school (where as a student he published an article in the law school’s flagship law journal — an extreme rarity for any student or practitioner) —
With all of this, Thomas D. Sykes may be your best choice to efficiently and effectively resolve your dispute with the IRS. He is not a bankruptcy, “business law,” divorce, estate-planning, probate, real-estate, immigration, or general-practice lawyer who dabbles in tax as needed; rather, he is a lawyer, at the top of his profession, who has focused upon intense federal tax disputes for the last 40+ years.
He will personally handle your dispute, and not hand some or all of it off to a junior partner, an associate, or a paralegal; this eliminates bureaucratic redundancies and fee duplication. His no-frills, quick-study, result-focused, “boutique” law firm offers judgment-informed solutions from energetic Redmond, WA — and emphatically not from Florida, Texas, California, or Michigan. His operating efficiencies allow his hourly rate to be well below the premium rate you would expect for a lawyer of this caliber.
What can this responsive, premier, nationally validated, senior member of the tax-dispute bar do for you?
Tom invites you to peruse this data-rich website (including its seven drop-down pages, its five click-on badges, three carousels, and several testimonials) for uncommonly specific details about Tom’s nationwide federal tax-dispute practice, and about his phenomenal, singular legal and tax background and experience. Then maybe use this web page as a checklist for comparisons, and . . .
Maybe Ask: Why Do So Many Other Tax Lawyers Tell You So Little About Their Experience, Accomplishments, Peer Recognition, and Even Location?
Premier Coast-to-Coast Federal Tax Lawyer ™
Singular IRS-Dispute Lawyer Serving Taxpayers Nationwide from Redmond, WA. His Focus Is upon IRS Disputes — All Types, Including Those with Criminal Worries.
Verifiable, Real-World, First-Chair Experience with the Largest Federal-Tax Disputes — Handled for Blue-Chip Clients on the Nation’s Biggest Stages.
Not a Small-Ball “Tax Dabbler” Who Primarily Focuses, with Federal Tax as a Possible Adjunct, Upon “Business Law,” Estate Planning and Probate, Divorce, Immigration, Personal Injury, Bankruptcy, or Real-Estate. Not an Accountant, and not an Enrolled Agent. Not a Tax Attorney Preoccupied with Washington State Excise, Business-and-Occupation, or Property Taxes. Not an Attorney Who Manages a Tax-Debt-Relief or Return-Preparation “Mill.” Rather, Tom is an IRS-Dispute Lawyer of the Highest Order — One Who First-Chair Represented the IRS in Federal Court for 17 Years, Receiving Four Promotions and Four Outstanding Attorney Awards in the Process.
So . . .You’ve Seen the Headlines: IRS Will Hire 30,000 New Employees over the Next Two Years. This Probably Is Not Good News If You Have Been Non-Compliant. Generally, It Is Better for a Taxpayer to Proactively Fix a Problem (Smartly) Before the IRS Comes Calling.
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First Chaired About $4 Billion of Federal Tax Disputes in the Federal Court “Crucible”
Practice Areas
Extensively Published in Premier Tax Publications; Co-Author of a Definitive BNA/Bloomberg Tax Treatise and of a Chapter Supplement to a Definitive Wolters Kluwer Treatise.
Co-Author, Chapter in BNA/Bloomberg’s Tax Practice Series, Addressing IRS Examinations
I am a retired Deloitte tax partner. During my career I had the pleasure of working directly with Tom Sykes on several mutual clients, some of whom I referred to Tom, given his deep knowledge and expertise. These were mostly large, high profile academic medical centers, universities and other not-for-profit entities. His advice and counsel is top notch. Truly an expert in the area of complex federal tax matters and litigation. Highly recommended.
Thomas R. Kromer
Your background is, without a doubt, phenomenal.
Legal Recruiter, Fortune 15 Corporation
A conflict between you and the IRS or SSA is not any fun. Finding a good partner to combat this is important and Tom Sykes is that individual. He knows the laws and he is a tireless, never-give-up individual combating for you every step of the way. Thank you, Tom, for being in my corner!