Ellis Reemer heads the Tax Controversy and Tax Disputes practice and has more than two decades of experience in tax controversy, tax disputes and tax litigation matters. He concentrates in representing clients in complex federal, state, and local tax controversies and tax litigation.

Mr. Reemer has represented both public and privately held corporations, as well as partnerships, estates, trusts and individuals. He regularly represents accounting firms and accountants in matters involving their obligations under federal and state tax laws.

Mr. Reemer has extensive experience in corporate, partnership, and individual tax disputes and has represented clients in tax disputes pending before the Internal Revenue Service throughout the United States, as well as in matters pending in the United States Tax Court, the US District Court, the Court of Federal Claims and the US Bankruptcy Court. Mr. Reemer recently has represented clients in connection with the Internal Revenue Service’s "tax shelter initiative," including matters relating to the tax shelter registration and list maintenance provisions of the Internal Revenue Code; "Promoter" Penalty Investigations; and tax controversies and tax disputes involving, among others, IRS Notice 2001-16 (intermediary transactions), IRS Notice 95-53 (lease stripping), IRS Notice 2001-17 (contingent liability transactions); and IRS Notice 2000-44 (partnership basis).

Mr. Reemer, in connection with the White Collar Group, also represents clients in connection with criminal tax matters, including investigations being conducted by the Criminal Investigation Division of the Internal Revenue Service and the Department of Justice.

Mr. Reemer has substantial experience representing clients in connection with complex state and local tax controversies, tax disputes and tax litigation, particularly with respect to matters pending before the New York State Department of Taxation and Finance and the New York State and New York City Tax Appeals Tribunals. Among his recent representations, Mr. Reemer has represented clients in connection with matters involving alleged unreported income and fraud; sales, use, and withholding tax audits, residency audits; and challenges to the allocation and apportionment of income.

Mr. Reemer’s experience also includes representing clients in connection with enforced collection proceedings brought by the Internal Revenue Service and state and local taxing authorities, including matters relating to lien priorities, bankruptcy, insolvency proceedings, and jeopardy assessments. Mr. Reemer has represented clients seeking offers in compromise and other payment agreements with federal, state, and local taxing authorities.

Prior to entering private practice, Mr. Reemer was a Senior Trial Attorney with the Office of Chief Counsel of the Internal Revenue Service. In that capacity, he represented the Internal Revenue Service in federal tax litigation in the United States Tax Court.

Mr. Reemer has conducted seminars for other tax professionals on various tax matters, including recent developments regarding “reportable transactions” and “material advisors,” and the attorney-client privilege and work product doctrine.

In 2008, he was named a New York Super Lawyer.

Admissions

• New York
• United States Supreme Court
• United States Tax Court
• United States District Court for the Southern District of New York
• United States District Court for the Eastern District of New York
• United States Court of Appeals for the Second Circuit
• United States Court of Federal Claims
• United States Court of Appeals for the Federal Circuit

Memberships

• American Bar Association, Tax Section, Member, Committee on Criminal and Civil Tax Penalties
• Formerly, Member of the Executive Committee of the Tax Section of the New York State Bar Association
• Formerly, Co-chair of the New York State Bar Association's Committee on Compliance, Practice and Procedure

Publications

• Co-author, "New York Taxpayers: Under New Law, Voluntarily Disclosing Past Tax Avoidance Averts Penalties, Prosecution," Practical U.S./Domestic Tax Strategies (World Trade Executive, Inc.), Volume 6, Number 6, August 2008

Seminars

• Moderator, “State and Local Tax Controversies,“ “IRS Audits and Appeals,” and “Litigating a Federal Tax Controversy,” Los Angeles Chapter, Tax Executives Institute (April 18, 2008)
• Panelist, "New Return Preparer Rules: Harsher Standards and Harsher Penalties--Is It Time to Retire Early?," American Bar Association Taxation Section meeting, Vancouver, British Columbia (September 29, 2007)
• Panelist, "New Federal Reportable Transaction Regulations," CLE program of Strafford Publications, Inc. (January 10, 2007)
• Speaker, “The Role of Attorney Client Privileges,” Atlas Information Group Seminar relating to “Handling IRS Audits” (July 10, 2006)
• 2005 U.S. Tax Court Judicial Conference Participant, by invitation of Chief Judge Gerber
• Speaker, "Tips from the Front Lines: Practical Strategies for Negotiating with the IRS," Association of the Bar of the City of New York's panel relating to Federal Tax Controversies (April 29, 2004)
• Panelist, "Issues Arising Out of the Representation of Tax Shelter 'Promoters' in IRS Audits," American Bar Association's Tax Section (September 13, 2003)
• 2001 U.S. Tax Court Judicial Conference Participant, by invitation of Chief Judge Wells