Taking A Cooperative Approach To Your Legal Issues
Steve is a 30-year veteran of the Internal Revenue Service's Office of Chief Counsel, serving first writing private letter rulings in domestic and international mergers and acquisitions, then as an IRS litigator before the U.S. Tax Court in Washington, D.C., and then as the Special Assistant to the Acting Chief Counsel in Washington, D.C. where he shared in the responsibility for management of the Office of Chief Counsel nation-wide. Among his nationally recognized achievements, he represented the government in the trial preparation and settlement of one of the largest corporate acquisitions in history. His achievements brought him to Sacramento to open and manage for fifteen years, the IRS law office as District Counsel for the newly-formed Sacramento District, where he was responsible for the management oversight, trial and settlement of a hundred million dollar inventory of cases before the United States Tax Court. As District Counsel in Sacramento, Steve was the IRS's top law enforcement attorney responsible for 31 Northern California counties.
Steve is admitted to practice in Massachusetts and Washington D.C. only. He is authorized to represent clients nationwide before the Internal Revenue Service and in U.S. Tax Court. He is not admitted in California. Steve is a founding member and past chairman of the Taxation Section of the Sacramento County Bar Association. He was also the IRS advisor to the Executive Committee of the State Bar of California's Taxation Section for nearly 10 years. Steve served as a member and vice chair of the Executive Committee of the State Bar of California's Taxation Section. He is the author of a major article on corporate acquisitions, currently cited in the leading treatise on corporate taxation as well as many other articles. He was an adjunct professor of law for over ten years at the University of the Pacific's McGeorge School of Law, where he taught federal tax practice and procedure, as well as federal criminal tax procedure. Steve has moderated and participated in many seminars and technical presentations for the State and County Bars as well as business and family laws groups.
Steve's practice focuses on all issues of federal tax controversy, including income, employment and excise tax audits and appeals, complex employment tax disputes, representation before the IRS in money laundering, structuring, tax evasion, fraud, and false return cases, offshore compliance issues such as the repatriation of foreign bank accounts and trusts, tax shelter projects and litigation, aviation fuels excise tax matters, Tax Court litigation, Voluntary Disclosures of offshore accounts, estate and gift tax audits and litigation, private letter rulings and technical advice, as well as representation before the IRS Office of Professional Responsibility in matters of professional and disreputable misconduct. Steve is also an expert in the exempt organization area and has represented local governments in federal employment tax matters. He is also an expert in all aspects of IRS collection work including obtaining installment agreements and Offers in Compromise, and the release or subordination of federal tax liens. Steve is often called on to provide expert advice in complex tax litigation, federal tax transactional planning, section 1031 real estate exchanges and business acquisitions.
- Georgetown University Law Center, Washington, District of Columbia
- Boston College Law School, Boston, Massachusetts
- Rutgers College, New Brunswick, New Jersey
- Honors: magna cum laude
- Honors: Phi Beta Kappa
- Major: Political Science
- Massachusetts, 1970
- District of Columbia, 1972
- U.S. District Court of the District of Columbia, 1972
- U.S. Tax Court, 1975
- IRS Abuse of Anti-Tax-Shelter Rules, Tax Notes Today, 152-86, 2006
- The IRS Unfairly Attacks the Tool Industry, Tax Notes Today, 84-47, 2005
- Charles Derby vs. Commissioner, T.C. Memo 2008-45, 2008, US Tax Court
- Phillips vs. Commissioner, 114 TC No. 7, 2000, US Tax Court
- Misc. Outstanding Performance Awards
Classes & Seminars
- Adjunct Professor of Law, University of the Pacific's McGeorge School of Law, 1999 to 2002
- Multiple Lectures and Seminars, CA State Bar, Taxation Section, 1984 to 2008
- Advisor and Member, Executive Committee, Taxation Section, CA State Bar, 1984 - Present
- Wide Range of Corporations
- Governmental Entities
- High Wealth Individuals, White Collar Defendants
- Widely Held Limited Partnerships
- Internal Revenue Service, Tax Law Specialist, Trial Attorney, 1970 to 1979
- Internal Revenue Service, Assist. to Dep. CC Dist.Counsel, Sacto, 1981 to 2002
- California State Bar Association, Taxation Section, Advisor, Executive Committee, 1986 to 1994
- California State Bar, Taxation Section, Member and Vice Chair, Executive Committee, 2004 to 2008
Steven J. Mopsick is a federal tax attorney and is not admitted in California. He is licensed in the District of Columbia. His practice is limited to matters before the Internal Revenue Service, the U.S. Treasury Department and the Unites States Tax Court. He does not advise or represent clients regarding California state tax matters.