The University of Baltimore Low-Income Taxpayer Clinic is pleased to announce that two of its student attorneys have secured full-time attorney positions with the Internal Revenue Service’s National Office of Chief Counsel in Washington, D.C. to begin in the fall of 2019.
Dominic DiMattia (J.D. anticipated May 2019) and Hayley Hassan (J.D. anticipated May 2019) were accepted under the Office of Chief Counsel’s Attorney Honors Program. This rigorous and competitive program is the sole channel for hiring by the IRS’s National Office of Chief Counsel, which provides legal support the IRS nationwide. As attorneys in that office’s Income Tax and Accounting Division, they will gain and apply expertise in a wide array of substantive tax areas and help implement and set IRS legal policy.
Mr. DiMattia served as a UB LITC student attorney in the spring and fall 2018 semesters, while Ms. Hassan served in the fall 2018 semester and was invited to return in the spring of 2019. As student attorneys, Mr. DiMattia and Ms. Hassan handled a wide variety of federal tax controversies, including collection matters, administrative disputes before the IRS, and litigation in various federal courts. In the fall 2018 semester alone, Mr. DiMattia prepared for trial and settled a factually complex matter in U.S. Tax Court, while Ms. Hassan litigated a U.S. District Court tax refund suit raising novel legal issues.
Mr. DiMattia said, “I attribute a big part of landing a job at the IRS to the Tax Clinic. Clinic was the place in law school where I learned the practical skills necessary to practice tax law. It allowed me to meaningfully contribute to the agency through my work.”
The IRS Honors Program is highly selective and draws applicants from law schools nationwide. Attorneys chosen for this honor often go on to successful careers in tax law both within and outside the government. Professor Snyder and the entire University of Baltimore LITC congratulate Mr. DiMattia and Ms. Hassan on achieving these coveted positions.
On December 6, 2018, Jack Snyder of the University of Baltimore Low-Income Taxpayer Clinic took part in a panel at the annual Low-Income Taxpayer Clinic Conference in Washington, D.C.
Professor Snyder spoke on the topic of “Effective Tax Administration Offers in Compromise.” Joining him on the panel was Professor Joshua Wease of the Michigan State LITC.
An Offer in Compromise allows a taxpayer to settle an outstanding tax debt with the IRS for less than the full amount due. Most Offers are based on doubt as to collectability, a demonstration that the taxpayer lacks the assets or monthly income to pay the tax liability in full. Effective Tax Administration (“ETA”) offers, on the other hand, allow taxpayers to settle a tax debt on the basis of general economic hardship or a variety of specific public policy reasons even if the taxpayer can otherwise afford to pay in full.
For example, as Prof. Snyder explained, many of the UB LITC’s clients have little or no net monthly income but are “asset-rich” due to retirement plan savings or equity in a home in Maryland’s high-value real estate market. Such taxpayers need to preserve these assets in order to survive and cannot use them to pay down their tax liabilities. In some cases, an ETA offer is the optimal tool to resolve such a taxpayer’s problem.
The panelists also discussed the rarer “public policy” ETA offers. One public policy basis for an offer, Prof. Snyder noted, is when the tax liability arose due to the crime or fraud of a third party, such as a withdrawal from the taxpayer’s retirement plan at the behest of a “friend” who then absconds with the money.
The panelists cautioned that ETA offers can be difficult to obtain. The IRS is less familiar with ETA offers than with other types. The panelists encouraged representatives considering submitting such offers to the IRS to research the relevant facts and law extremely thoroughly and to be prepared to educate the IRS employee handling the matter. Even then, success is not guaranteed.
The LITC Conference is presented annually by the LITC Program Office of the Taxpayer Advocate Service. All directors of low-income taxpayer clinics nationwide attend the conference, where they share information on emerging issues and legal challenges faced by low-income taxpayers.
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