Guinevere M. Moore
- Court Admissions
- Professional Associations
- Community Involvement
- Upcoming Speaking Engagements
Guinevere Marie Moore is a tax litigator who represents taxpayers in civil and criminal tax controversies. She advocates for taxpayers at the IRS examination and appeals levels and, if a settlement with the IRS cannot be reached, in litigation.
She has litigated procedural and substantive aspects of partnership disputes, and she understands there are unique tax consequences to partnerships that must be handled effectively. Her experience representing clients before the IRS as an attorney well-qualifies her to represent partnerships as a partnership representative. Ms. Moore is able to easily identify and efficiently resolve those disputes with the IRS that can be quickly disposed of, and is able to advise her clients when they need to gear up for a larger fight.
Ms. Moore has represented taxpayers throughout her career, and draws on her experience in working with her clients, with the IRS, and with opposing counsel to help craft and execute the best possible plan to resolve the issues her clients are facing. Ms. Moore has successfully defended taxpayers against assessment of all types of federal tax, including income tax, employment tax, estate tax, gift tax, civil penalties, and criminal penalties.
Ms. Moore’s significant experience in practicing before the IRS and in the United States Tax Court enables her to work together with her clients to determine the best path forward to resolving the tax dispute – whatever Internal Revenue Code section may be at issue. The Internal Revenue Code contains thousands of provisions, and no tax professional has encountered them all. But having years of experience with the procedural hurdles that a taxpayer has to jump through in order to resolve a disagreement with the IRS over how much tax is due facilitates a much easier journey towards agreement or resolution through litigation.
Ms. Moore particularly enjoys the client counseling that she performs in her role as a taxpayer’s advocate. Having navigated hundreds of disputes with the IRS she is able to guide clients through what is often the most difficult crisis they are facing in their lives. Her clients will never wonder what comes next, or how the most recent development will impact them, because Ms. Moore routinely explains the process, the anticipated timeline, our strategy, and how all of the pieces come together. Ms. Moore will either partner with a client’s existing accountant, or, if necessary, engage a new accountant under a Kovel agreement.
Ms. Moore is actively involved in the American Bar Association, Section of Taxation. She is the Chair of the Standards of Practice Committee of the Section of Taxation. In that role, she designs programming designed to ensure certain ethical standards are met in tax representation nationwide. ABA Tax Times recently published an interview with Ms. Moore. Ms. Moore is also actively involved in the Accounting and Financial Women’s Alliance (AFWA), where she will be serving as a Member of the Board of Directors in summer of 2020. In 2020 she is co-chairing the AFWA’s national conference, Women Who Count, which will be held at the Drake Hotel in Chicago.
Ms. Moore draws on her many years of experience as a member of the Tax Bar to provide advice and insight to others. She is a co-author of Incompetent Authority, (a play on Competent Authority, the person legally designated authority to opine on matters of double taxation), a humorous advice column for tax lawyers published in ABA Tax Notes.
Ms. Moore is a frequent speaker at national and local conferences on topics related to tax, ethics, and the ethics of tax. Ms. Moore launched what has become an active pro bono program designed to help low income taxpayers receive representation that they could otherwise not afford. As part of this process, she co-authored and designed a four-part training series for representing low-income taxpayers before the IRS. She has been recognized for her pro bono work as the volunteer of the year by LadderUp, and has represented over one hundred clients pro bono.
Ms. Moore lives in Chicago with her husband and her four children. While she lives in Chicago, she represents taxpayers all across the United States and the world.
Ms. Moore has significant experience representing taxpayers in United States Tax Court. Ms. Moore has defended partnerships in IRS audits at the IRS examination and IRS appeal level, as well as in litigation. Her tax court experience includes taking cases from initial examination all the way through trial and appeal, as well as negotiating settlements favorable to the taxpayer.
Ms. Moore routinely defends clients in Information Reporting examinations, and has successfully defended clients from penalties for the failure to file information returns or from disputed information returns including 3520, 5741, and FBAR. She recently published Information Return Penalties: How to Avoid or Contest Them in The Tax Advisor. Ms. Moore also routinely advises U.S. taxpayers from around the world regarding how to expatriate from the United States, and recently published U.S. Citizens Living Abroad Should Consider Taking Advantage of New Relief Procedures in Bloomberg Tax.
She is well-versed in all manner of IRS examinations and has defended taxpayers at IRS Examination level run by both Small Business / Self Employed, Large Business & International. She also defends taxpayers at IRS Appeals, and pursuing claims for refund.
In her role as Executive Director of U.S. Partnership Representative, Ms. Moore has become a go-to resource for partnerships seeking a partnership representative or assistance with revising partnership agreements to comply with the Bi-Partisan Budget Act of 2015.
*Results in past cases should not be considered to be an indication of future results.
- DePaul University College of Law, Chicago, Illinois
- J.D. – 2008
- Honors: cum laude
- DePaul University
- B.A. – 2003
With Highest Honors
- Supreme Court of Illinois
- U.S. District Court Northern District of Illinois, Member of the Trial Bar
- U.S. District Court Central District of Illinois
- U.S. District Court Eastern District of Wisconsin
- U.S. District Court Western District of Wisconsin
- U.S. Court of Appeals 1st Circuit
- U.S. Court of Appeals 3rd Circuit
- U.S. Court of Appeals 6th Circuit
- U.S. Court of Appeals 7th Circuit
- U.S. Court of Appeals 8th Circuit
- U.S. Court of Appeals 9th Circuit
- U.S. Court of Appeals 10th Circuit
- U.S. Court of Appeals 11th Circuit
- U.S. Court of Appeals Federal Circuit
- U.S. Court of Federal Claims
- U.S. Tax Court
- Supreme Court of the United States
In addition to these publications, attorney Guinevere Moore is a regular tax contributor to the Forbes blog, which you can view here.
- Guinevere Moore co-authored Summer 2020 issue of ABA Tax Times. View here.
- Is It Time for an Engagement Check-up? by Guinevere Moore, Journal of Tax Practice & Procedure, December 2019-January 2020.
- IRS Announces Tax Attorney as New OPR Director. To read the article in its entirety, click here.
- ‘Low Bono’ Options Offer More Ways to Aid Middle-Income Taxpayers. To read the article in its entirety, click here.
- Information Return Penalties: How to avoid or contest them, The Tax Advisor Guinevere Moore explores the vast Information Return Penalties the IRS has at its disposal and how taxpayers who are facing these penalties can avoid them or, if they are assessed, contest them.
- Virtual Currency Reality: The IRS Crack Down on Cryptocurrency, Journal of Tax Practice and Procedure Guinevere Moore examines the filing obligations for cryptocurrency holders, past IRS enforcement and IRS guidance, and next steps for IRS enforcement and cryptocurrency holders.
- U.S. Citizens Living Abroad Should Consider Taking Advantage of New Relief Procedures by Guinevere Moore, Bloomberg Tax Daily Tax Report, Insight. Guinevere Moore explores the benefits and guidelines of an IRS program announced on September 6, 2019 regarding new relief procedures available to taxpayers living outside the United States who wish to expatriate. For those who qualify, the terms of the program are quite generous. For those U.S. citizens who live outside the United States and are not in compliance with the IRS, an IRS examination may be on the horizon.
- IRS Fumble: What to Do When a Tax Assessment’s Validity is Questionable by Guinevere Moore, ABA Tax Times, June 14, 2019. Back-to-back opinions released by the United States Tax Court on May 20 and May 21 of 2019 serve as compelling reminders that what we learned in kindergarten is true: the same rules really do apply to everyone. When the IRS does not follow required procedures, the Tax Court will not hesitate to invalidate an assessment and find for the petitioner. To read the article in its entirety, click here.
- Preparing Partnership Returns Under the BBA by Guinevere Moore and Elizabeth Yablonicky, Journal of Tax Practice and Procedure, February-March 2019Tax return preparation is not for the faint of heart. Return preparers are expected to understand and advise their clients on a myriad of ever-changing tax issues, from what type of entity will provide the best tax advantages for a business to which deductions have been created, expanded, or eliminated under the tax code. Clients expect their tax professionals to have all the answers to their tax-related questions and to be able to help them keep taxes as low as legitimately possible. To read the article in its entirety, click here.
- A Primer on Deducting Losses from Real Estate Activities for “the Rest of Us” by Elizabeth Yablonicky and Guinevere Moore, ABA Tax Times, February 22, 2019Your client has been reading the news about deducting real estate losses and comes to you wanting to know: why didn’t you tell me about all the deductions I could have been taking for my rental real estate losses? And can I pay a lower tax rate on my gains? You explain to your client that it is much harder to deduct real estate losses than the current news makes it seem. But your client, who owns several businesses, only one of which is real estate, wants to know – how do I start taking advantage of this deduction? To read the article, click here.
- The Sixth Amendment guarantees the right to conflict-free counsel in a criminal case. In addition to the obvious question of whether an attorney can represent co-defendants in a white-collar criminal case, there is the less obvious question of whether the attorney owes a professional duty to non-clients: the criminal defendant’s spouse and children. Whether an attorney owes a professional duty to a non-client, including the spouse of a client, depends on the state where the representation takes place. To read the article, click here.
- Reasonable-Reliance Defense and Work Product Protection by Guinevere Moore, ABA Tax Times, March 2018In Estate of Marion Levine v. Commissioner, Docket No. 13370-13, the United States Tax Court issued a designated Order that granted the petitioner’s motion to limit the scope of an IRS subpoena duces tecum served on petitioner’s prior counsel. Attorneys from the Estate’s first law firm of record completed the estate planning during the decedent’s life, prepared and filed the estate tax return, defended an IRS examination, and, when the outcome of the examination wasn’t favorable to the Estate, filed a petition in Tax Court after the Notice of Deficiency was issued in 2013. The original law firm’s representation of the Estate continued through 2015, when new counsel entered an appearance on behalf of the Estate. To read this article, click here.
- American Bar Association
- Chicago Bar Association
- American Bar Association, Section of Taxation
- Chair of the Standards of Practice Committee (Tax Ethics)
- Chair of the Janet Spragens Pro Bono Award Committee
- Chicago Bar Association, Taxation Committee
- Accounting and Women’s Financial Alliance, Member of the Board of Directors
- Chicago’s Notable Women Lawyers, Crain’s
- Rising Star, Illinois Super Lawyers Magazine
- Volunteer Champion Award, Center for Economic Progress (CEP)
- Nolan Fellowship, American Bar Association Section of Taxation
- Public Interest Law Initiative Fellow, Domestic Violence Legal Clinic, Chicago
- Volunteer of the Year, LadderUp
- March of Dimes, Board Member
- Women Who Count, National Conference, Co-Chair, 2020 to 2020
Upcoming Speaking Engagements
10/28/2020 – 10/30/2020
Guinevere Moore is serving as Co-Chair of Women Who Count. Register and Learn more here.
Previous Speaking Engagements
8/25/2020 – 8/26/2020
Guinevere Moore is presenting “When is it time for an Engagement Checkup?” at the Illinois CPA Society Summit. Register and learn more here.
7/27/2020 – 7/30/2020
Guinevere Moore is presenting “Best Practices for Defending an IRS Examination” at the National Association of Tax Professionals 2020 National Conference and Expo in San Antonio. Register and learn more here.
Guinevere Moore is presenting “Real Estate 199A Aggregation and 469 Grouping Rules: Real Estate and Safe Harbor Election” for Strafford.
5/1/2020 – 5/3/2020
Guinevere Moore is participating in the American Bar Association Section of Taxation 2020 May Meeting. She will be Chairing the Standards of Tax Practice Committee and Presenting, “Ethical Issues in Handling a Matter in Tax Court” Register and learn more here.
4/1/2020 – 4/3/2020
Guinevere Moore is presenting “Who is Being Audited and What Should you Do About It?” at the 20th American Bar Association Section of Taxation Annual U.S. and Europe Tax Practice Trends in Munich. Register here and learn more here
1/30/2020 – 2/1/2020
Guinevere Moore presented on a two-part series entitled Ethical Issues Related to Limited Scope Engagements and Chaired the Standards of Tax Practice Committee for the American Bar Association Section of Taxation Mid-year Meeting in Boca Raton January 30 – February 1, 2020.
Guinevere Moore presented It’s a Whole New World, Defending and Litigating Partnership Adjustments Under the Bi-Partisan Budget Act of 2015 at the American Bar Association Section of Taxation National Institute of Criminal Tax Fraud and Tax Controversy on December 12, 2019.
Guinevere Moore presented The Obligation to Report Tax Related Misconduct at the New England IRS Tax Representation Conference on November 22, 2019.
Guinevere Moore presented Seeing through the Haze, Navigating Legalized Cannabis in Illinois at the Chicago Bar Association on November 13, 2019.
7/23/2019 – 7/25/2019
Guinevere Moore has been selected to present at the IRS Nationwide Tax Forum on “Tax Treatment of Transactions in Cryptocurrency and IRS Tax Enforcement”. You can register for the Forum in Chicago being held July 23 – 25 here, or in Orlando being held August 13-15 here.
Guinevere Moore will take part in a live webinar “Real Estate 199A Aggregation and 469 Grouping Rules: Real Estate Professionals and Safe Harbor Election” on July 2, 2019 at 12:00 p.m. CST. (Available from Strafford)
Guinevere Moore will be part of a panel for a live webinar entitled “Amending LLC and Partnership Agreements to Address Tax Reform and the Current IRS Audit Rules: Tax Law Considerations, Former Partner Contributions to Tax Liability, Push-Out Elections and More”, on June 25, 2019 at 12:00 p.m. CST (Available from Strafford)
6/20/2019 – 6/21/2019
Rock–Partnership Representative–Hardplace, NYU Tax Controversy Forum, New York, NY, June 20-21, 2019
5/10/2019 – 5/11/2019
Representing Taxpayers During Summons and Other IRS Interviews, ABA Section of Taxation 2019 May Tax Meeting, Washington DC, May 10-11, 2019
Updated Voluntary Disclosure Practices: Is this the Correct Path for your Noncompliant Client?, Federal Bar Association Tax Law Conference, Washington, DC, March 9, 2019
Guinevere Moore presented Partnership Representatives: IRS Regulations Under Section 6223 and Challenges for Pass-Through Entities on February 13, 2019 through Strafford, program download is available here.
Guinevere Moore hosted a live webinar called “Partnership Representatives: New IRS Final Regulations Under Section 6223 and Challenges for Pass-Through Entities” on January 30, 2018. The webinar record is available from Strafford.
What Everyone Needs to Know about Cryptocurrency: Part One: Tax Treatment of Cryptocurrency Transactions; Part Two: Enforcement When Cryptocurrency Transactions Go Wrong, 35th Annual National Institute on Criminal Tax Fraud, Las Vegas, NV, Dec. 15, 2018
Civil Tax Workshop: Responding to Summonses, ABA 35th Annual National Institute on Criminal Tax Fraud, Las Vegas, NV, Dec. 13, 2018
10/4/2018 – 10/6/2018
Ethical Issues Regarding Partnership Representatives, ABA 2018 Fall Tax Meeting, Atlanta, GA, Oct. 4-6, 2018
10/4/2018 – 10/6/2018
Advise on Extending Statute of Limitation, ABA 2018 Fall Tax Meeting, Atlanta, GA, Oct. 4-6, 2018
Reasonable Reliance Defense and Work Product Protection, Federal Bar Association 42nd Annual Tax Law Conference, March 9, 2018
Ethical Issues/Experts in Federal Tax Practice, Federal Bar Association 42nd Annual Tax Law Conference, March 9, 2018
2/8/2018 – 2/10/2018
280E – Current Law and Analysis, ABA Tax Section 2018 Midyear Meeting, San Diego, CA, February 8-10, 2018
2/8/2018 – 2/10/2018
Preparing Witnesses to Testify, ABA Tax Section 2018 Midyear Meeting, San Diego, CA, February 8-10, 2018
Marijuana: Ethical and Legal Issues in Representing Taxpayers, ABA 34th Annual National Institute on Criminal Tax Fraud and Seventh Annual National Institute on Tax Controversy, December 6, 2017
Ethical Issues in Preserving and Collecting Evidence, ABA Tax Section 2017 May Meeting, May 12, 2017
Responding to IRS Penalties, IRS Nationwide Tax Forum, Chicago, IL, July 13 and 14, 2016
Nuts and Bolts of Tax Court Litigation: Trial, ABA Mid-Year Meeting, January 2016
Disclosure, FOIA and Tax Litigation, ABA Mid-Year Meeting, January 2016
Unreported Offshore Assets – Disclosures and Audits 3rd Annual International Tax Enforcement Conference, October 16, 2015
American Bar Association’s 2015 Joint Fall CLE Meeting Ethical Issues Arising in Discovery; Kicking the Habit: Using Kovel Responsibly; Aggressive IRS Audit Techniques – Tales from the Trenches (Moderator), September 17-19, 2015 Initiating a New Client Engagement – Ethical and Practice Standards American Bar Association, Section of Taxation, May Meeting, Washington, D.C., May 8, 2015
American Bar Association Section of Real Property, Trust and Estate Law 2015 Spring Symposia CLE Meeting Moderator, Get Ready: Global Tax Enforcement is on the Rise for High-Wealth Taxpayers, April 30-May 1, 2015 Career in Tax Law Panel Northwestern University School of Law, March 18, 2015
1/29/2015 – 1/31/2015
American Bar Association Section of Taxation 2015 Midyear Meeting Ethical Issues in Federal Tax Practice – The Government Perspective, January 29-31, 2015
The Illinois CPA Society 2014 Tax Conference Offshore Tax Compliance: Often Forgotten Informational Forms and the IRS’s Offshore Voluntary Disclosure Programs, November 12, 2014
11/5/2014 – 11/8/2014
American Association of Attorney-Certified Public Accountants (AAA-CPA) Fall Meeting and Education Conference Offshore Tax Compliance: Often Forgotten Informational Forms and the IRS’s Offshore Voluntary Disclosure Programs, November 5-8, 2014
American Bar Association Section of Taxation 2013 May Meeting Moderator, Ethical Issues in Federal Tax Practice – The Government Perspective, May 10, 2013 Proposed Circular 230 Regulations: Adopting a Principles-Based Approach to Written Tax Advice Annual Philadelphia Tax Conference, November 14, 2012
9/13/2012 – 9/15/2012
American Bar Association Joint Fall CLE Meeting Panelist, Addressing Concerns About the Ethical Judgments for a Supervising Attorney; Moderator, Ethical Issues in Federal Tax Practice – The Government Perspective, September 13-15, 2012