About the Department of Justice

The United States Department of Justice (“DOJ”) litigates tax cases on behalf of the federal government.

Within the DOJ, the Tax Division is responsible for handling a wide range of civil and criminal tax matters, working closely with the IRS to enforce the nation’s tax laws and ensure compliance.

The DOJ typically serves as the attorney in tax litigation cases and its client is the IRS. This means that the attorney working the case is a department of justice attorney rather than an IRS attorney.

Civil Tax Litigation

While IRS attorneys represent the agency in cases before the U.S. Tax Court, DOJ attorneys handle civil tax litigation in other federal courts, including U.S. District Courts, the U.S. Court of Federal Claims, U.S. Courts of Appeals, and the U.S. Supreme Court. These cases may involve tax refund suits, tax shelter promoter injunctions, and other complex civil tax issues.

The Tax Division’s civil sections, organized by region, are staffed by experienced trial attorneys who specialize in tax law. These attorneys work diligently to protect the interests of the United States in civil tax controversies, seeking to ensure that taxpayers fulfill their obligations under the tax code.

Criminal Tax Enforcement

In addition to civil litigation, the DOJ Tax Division plays a central role in criminal tax enforcement. The Division’s experienced prosecutors work closely with IRS Criminal Investigation special agents and other law enforcement agencies to investigate and prosecute individuals and businesses that engage in tax fraud, evasion, and other criminal tax offenses.

The Tax Division’s criminal enforcement sections are organized into three regional sections (Northern, Southern, and Western) and the Criminal Appeals and Tax Enforcement Policy Section. These sections are responsible for reviewing evidence, authorizing grand jury investigations, approving indictments, and prosecuting criminal tax cases in federal courts across the country.

DOJ prosecutors handling criminal tax matters adhere to the policies and procedures outlined in the Tax Division’s Criminal Tax Manual, which serves as a comprehensive guide for the federal criminal tax enforcement program. This manual, similar in function to the IRS’s Internal Revenue Manual, is available to the public on the DOJ website.

Leadership and Resources

The Tax Division is led by the Assistant Attorney General (“AAG”), a Presidential appointee confirmed by the Senate. The AAG oversees a team of more than 300 attorneys, as well as administrative staff, who work primarily in Washington, D.C., with a smaller office located in Dallas, Texas.

The Division’s attorneys bring a wealth of experience and expertise to their roles, ensuring that the United States is well-represented in both civil and criminal tax matters. Their efforts are essential to maintaining the integrity of the nation’s tax system and promoting compliance with federal tax laws.

Experienced Tax Litigation Counsel

For taxpayers involved in tax litigation, whether before the U.S. Tax Court, U.S. District Courts, or the U.S. Court of Federal Claims, having skilled legal representation is crucial. Our team of experienced tax attorneys is dedicated to providing the highest quality legal services to clients facing complex tax controversies.

If you have questions about a tax litigation matter or need assistance with a case, we encourage you to schedule a consultation with one of our knowledgeable tax attorneys. We are here to guide you through the process and work towards a favorable resolution of your tax dispute. Contact us today to learn more about how we can help protect your rights and interests in tax litigation.

If you have questions about a tax litigation matter, we want to hear from you. Schedule an appointment with our tax attorneys online.