Joel N. Crouch
Mr. Crouch is a partner with Meadows, Collier, Reed, Cousins & Blau, L.L.P., specializing in civil and criminal tax controversies. He represents a broad range of clients, including individual taxpayers, closely-held business enterprises, estates, corporations and tax advisors in all stages of federal civil and criminal tax proceedings. Over the past 20 years, he has helped his clients resolve hundreds of civil and criminal tax matters, many of which involved sophisticated and complex legal and tax issues, both domestic and international.
Mr. Crouch has extensive experience in resolving tax matters at all stages of a tax dispute including IRS examinations, administrative appeals, and if necessary, litigation in the U.S. Tax Court, the U.S. Court of Federal Claims and U.S. District Courts. As a trial attorney, Mr. Crouch has tried major cases to verdict. In partnership litigation, he has been involved in challenging IRS positions on the enforceability of several federal regulations, the applicable statute of limitations and application of penalties.
As a board certified tax lawyer by the Texas Board of Legal Specialization, Mr. Crouch has intimate knowledge of the tax laws, regulations, accounting standards and developments within the IRS and other federal government agencies. His specialized knowledge and experience allows him to effectively advocate on behalf of his clients in litigation against the federal government. He has represented accountants and attorneys in civil promoter examinations and criminal investigations arising from their involvement in structured transactions. He has successfully navigated these investigations so that his clients’ exposure to penalties and criminal prosecution has been eliminated or significantly reduced.
Mr. Crouch has been recognized as one of the best in his field by Texas Monthly and Law and Politics magazines by being named a Texas Super Lawyer from 2003 through 2009. He is a frequent speaker on both substantive and procedural tax issues for both legal and accounting professionals. Topics include tax shelter defense, IRS examinations, appeals, litigation and collection strategies, IRS criminal investigations, IRS offshore activities, IRS focus on tax professionals, independent contractor versus employee, IRS penalties, and litigating partnership tax cases.
Education
- J.D., University of Texas School of Law, 1988
- B.A., Southern Methodist University, 1985
Bar Admissions
- State Bar of Texas
Professional Associations and Memberships
- American Bar Association, Taxation
- Member, Court Procedure and Practice Committee
- Member, Standards of Tax Practice Committee
- Member, Civil and Criminal Penalties
- Dallas Bar Association
- Tax Section Council, 2005-2006
- Dallas Bar Foundation
- Fellow
- Collin County Bar Association
- Plano Symphony Orchestra, Board of Directors, Secretary and Treasurer
Publications
- “6 Keys to Avoiding Section 6701 Penalties”, The Value Examiner, May/June 2006 Issue, National Association of Certified Valuation Analysts
2010 Speaking Engagements
- National Constitution Center Audio Conferences, Dallas – 2/17/10 & 6/15/10
- San Angelo Chapter/TSCPA, San Angelo – 5/19/10
- Central Texas Chapter/TSCPA CPE Expo, Waco – 5/20/10
- Fort Worth Chapter-American Society of Women Accountants, Ft. Worth – 5/26/10
2009 Speaking Engagements
- ABA Section of Taxation 2009 Mid-Year Meeting (Civil & Criminal Tax Penalties), New Orleans, LA – 1/10/09
- Estate Planning Council of Central Texas, Austin – 1/29/09
- Corpus Christi Chapter/TSCPA 51st Annual Tax Conference, Corpus Christi – 2/3/09
- National Constitution Center Audio Conferences, Dallas – 2/11/09
- Dallas Bar Association Family Law Section, Dallas – 4/8/09
- National Constitution Center Audio Conference, Dallas – 5/13/09
- Dallas Bar Association Family Law Section, Dallas – 7/8/09
- San Antonio Chapter/TSCPA CE Symposium, San Antonio - 8/20/09
- National Constitution Center Audio Conference, Dallas - 9/16/09
2008 Speaking Engagements
- National Constitution Center for Audio Conferences, Dallas – 1/9/08
- North Texas Estate and Financial Planning Council Seminar, Wichita Falls – 7/11/08
- Ft. Worth Chapter/TSCPA Tax Institute, Ft. Worth – 8/1/08
- Panhandle Chapter/TSCPA 24th Annual Tax Institute, Amarillo – 8/27/08
- ACPEN Partnership Tax Update, Dallas – 9/17/08
- Permian Basin Chapter/TSCPA 2008 CPE Expo, Odessa – 11/6/08
- TSCPA CPE Expo, Houston and Arlington – 12/01/08, 12/10/08
- The Knowledge Congress Webinar, Dallas – 12/4/08
- Society of Louisiana CPAs Tax Conference, New Orleans, LA – 12/15/08
2007 Speaking Engagements
- Ft. Worth Chapter/TSCPA Tax Institute, Ft. Worth – 8/23/07
2006 Speaking Engagements
- Southern and Western Accounting Group, Dallas – 6/6/06
- National Constitution Center Audio Conference, Dallas – 8/17/06
- Panhandle Chapter/TSCPA Tax Institute, Amarillo – 8/22-23/06
- Texas Tech Tax Institute, Lubbock – 10/19/06
- Corpus Christi Chapter/TSCPA Annual Tax Conference, Corpus Christi – 10/20/06
- Meadows Collier Taxation Conference, Dallas – 10/24/06
- Dallas Bar Association Tax Section, Dallas – 11/6/06
- West Texas Tax Institute, El Paso Chapter/TSCPA, El Paso – 11/30/06
Honors and Awards
- Texas Super Lawyers, Texas Monthly and Law and Politics Magazine, 2003 through 2009
Civil Tax Controversies Representation Matters
- Represented client in a successful challenge to the IRS' attempt to retroactively apply a Treasury regulation.
- Represented client in successfully resolving issues regarding unfiled payroll tax returns for multiple years.
- Represented estate in an IRS challenge to the value of interest in a closely-held business. Successfully settled case for significantly less than the IRS’s proposed assessment.
- Represented a client in IRS challenge to losses arising from investment in distressed assets.
- Represented attorney in a challenge to IRS summons for records related to attorney’s client’s offshore activities.
- Represented numerous clients in tax shelter examinations and civil litigation.
- Represented clients in IRS attempt to reclassify losses associated with horse and cattle activities as hobby losses under IRC § 183.
- Represented clients in IRS challenges to classification of independent contractors versus employees.
- Represented numerous tax professionals under investigation for alleged ethical and IRS Circular 230 violations.
- Represented large public company in an IRS challenge to deduction of expenses related to merger with competition.
- Represented owner and closely-held business in IRS examination of issues related to change in accounting method.
- Represented client in IRS attempt to impose penalties during litigation of civil tax matter. Successfully convinced court that the government could not propose penalties.
- Represented client in connection with IRS challenge to losses arising from failed tender offer for a foreign publicly-traded company.
- Represented numerous estates in IRS challenges to the valuation of closely-held businesses and estate planning vehicles fractionalizing ownership and control.
- Represented numerous estates in IRS challenges to family limited partnerships involving IRC §§ 2703, 2704 and 2036 and other substance-over-form attacks.
White Collar and Criminal Tax Controversies Representation Matters
- Hired by client post-indictment in mail and wire fraud case and convinced the government to dismiss the indictment before trial.
- Successfully avoided criminal prosecution and civil fraud penalties for numerous taxpayers in civil IRS examinations and IRS administrative proceedings with high risk of civil fraud penalties, criminal prosecution or both.
- Represented numerous clients in making voluntary disclosures to the IRS regarding unfiled tax returns, substantiation tax issues and offshore activities to avoid criminal prosecution.
- Represented large national corporation in investigation of potential environmental criminal violations. Convinced the government that no criminal charges should be brought.
- Represented an attorney in an IRS investigation of failure to file tax returns.
- Represented a hospital chain in a healthcare fraud investigation following the execution of search warrants based on allegations made by a qui tax relation.
- Represented a real estate investor indicted for tax fraud associated with losses for investment in bank-related real estate. The client was acquitted on all counts.
- Represented a banker indicted for allegedly failing to disclose relationship to borrowers who later defaulted on loan. The client was acquitted on all counts.
