Attorneys  

Josh O. Ungerman

Mr. Ungerman’s practice includes estate planning and family wealth transfers along with IRS controversy matters at all levels. The tax and estate matters in which Mr. Ungerman is involved are typically very complex from both a factual and legal perspective. These matters often require legal and accounting skills. Mr. Ungerman is also a Certified Public Accountant.

Mr. Ungerman works with the families on wealth preservation and transfer strategies. A major focus is on accomplishing family wealth preservation goals with an emphasis on the efficient transfer of family wealth to the next generation from a business and tax perspective.

Mr. Ungerman is also involved in defending Taxpayers & issues against IRS inquiries and actions. The IRS defense practice covers Civil and Criminal Exams, Investigations and Trials. Many of Mr. Ungerman’s Tax Controversy matters include an offshore component.

Prior to joining the firm in 1994, he was a civil prosecutor for the Internal Revenue Service, Dallas District Counsel office. He was also a Special Assistant United States Attorney for the Department of Justice in Dallas during his time as a civil prosecutor.  Prior to becoming an IRS attorney of a special assistant U.S. attorney, he served as a law clerk to the Honorable Carolyn M. Parr at the United States Tax Court in Washington, D.C. 

Mr. Ungerman is a frequent speaker on tax topics including exams, IRS estate tax strategies, tax shelter defense, recent tax legislation, IRS criminal tax investigation techniques, and state tax controversy issues.  He published an article in the April 2016 issue (Volume 41, Number 4) in the Dallas Bar Association Headnotes on, "Summer Vacation in the Caribbean - Not so Fast" .   Mr. Ungerman has a blog on Forbes IRS Watch.  Read and follow his blogs, http://www.forbes.com/sites/irswatch/#59e9e2cf6de0.  Mr. Ungerman published an article in the Fall 2014 issue of the Texas Tax Lawyer on "Are Virtual Currencies Such as Bitcoin the Next Tool for Tax Evaders - The IRS is Watching and You Might Be Surprised What They See."  He published an article, "A Practical Guide to the New Round of IRS Examinations" in the Fall/Winter 2012, (Volume 31, No. 3) of the Petroleum Accounting and Financial Management Journal published by the Institute of Petroleum Accounting at the University of North Texas. Mr. Ungerman is quoted in a BNA Daily Tax Report article on January 16, 2014 titled, "Julius Baer Decision Offers Little Safety For Hidden Swiss Accounts, Attorneys Say" by Alison Bennett and Daniel Pruzin and December 20, 2013 titled, "Swiss Banks Under Pressure as Deadline Nears for DOJ Program to Find U.S. Accounts" by Alison Bennett.  Mr. Ungerman is quoted in BNA's Daily Tax Report on August 15, 2011 in an article titled, "Taxpayers Fear Disclosing Offshore Assets As Deadline Approaches, Practitioners Say."  He is quoted in an article, "Fairness and Transparency Still Problems for OVDP" by Andrew Velarde in Tax Notes Today in Tax Analysts, January 15, 2015, "Second Circuit Reverses Convictions of 2 Former E&Y Shelter Promoters" in Tax Notes by Tax Analysts, November 30, 2012,  "The IRS's Misguided Fraud Whodunit" by Jeremiah Coder in Tax Notes by Tax Analysts, October 1, 2012,  "Applying Mayo, Federal Circuit Defers to Controversial Overstated Basis Regulation, by Jeremiah Coder in Tax Notes by Tax Analysts, March 14, 2011 and also in the article, "Seventh Circuit Overturns Tax Court on Gross Income Omission" by Jeremiah Coder in Tax Notes by Tax Analysts, January 31, 2011.  Alan K. Davis and Josh O. Ungerman published an article, "An Untaxing Year" in the December 20, 2010 Texas Lawyer, Vol. 26., No. 38.  Josh O. Ungerman is quoted in an article, "Hackers Offering Romney's Tax Returns Face Serious Punishment if Caught" by William Hoffman in the Daily Tax Report , September 7, 2012, and "IRS Withdraws 'John Doe' Summons Against UBS Over Tax Fraud Allegations" by Daniel Pruzin (Geneva) and Alison Bennett (Washington) in the Daily Tax Report, November 17, 2010.  Mr. Ungerman was quoted in three Tax Practice articles (published weekly by TaxAnalysts) on May 24, 2010, "IRS Undeterred After Tax Court's Intermountain Decision", April 12, 2010, "IRS Help for Struggling Taxpayers Contrasts With Enforcement Push" and on April 5, 2010, "Federal Circuit Overturns Penalty Determination in Jade Trading".   Mr. Ungerman is also quoted in an article published on taxanalyst.com entitled, "Swiss Agree to Expedite Processing of 4,450 UBS Accounts Under Treaty Request" by David D. Stewart on August 20, 2009.  He was also quoted in an article on bloomberg.com entitled, "Billionaire Tax Felon Says UBS Lied in Pledge to Report to IRS" by David Voreacos on June 9, 2009.  Another article he was quoted in was published on moneylaundering.com entitled, "Uptick in Tax Evasion Disclosures Mean More Bank Investigations, Say Attorneys" by Matt Squire on November 5, 2008.  Mr. Ungerman is quoted in the book, “The Cheating of America: How Tax Avoidance and Evasion by the Super Rich Are Costing the Country Billions–and What You Can Do About It" by Charles Lewis and Bill Allison and the Center for Public Integrity.

Mr. Ungerman was admitted to practice in Texas in 1990.

Education

  • J.D., Southern Methodist University School of Law, 1990
    • Board of Editors, Southwestern Law Journal
  • B.B.A., University of Texas at Austin, 1987

Bar Admissions

  • State Bar of Texas

Professional Associations and Memberships

  • Dallas Bar Association
    • Past Chair, Tax Section
  • State Bar of Texas
    • Past Chair, Tax Controversy Committee
  • American College of Tax Counsel
    • Fellow
  • American Bar Association
    • Member, Appointments to the Tax Court Committee, Tax Section, 2015-2017
    • Chair, Civil and Criminal Tax Penalties Committee, Tax Section
    • Past Chair, IRS Investigations and Practices Subcommittee, Tax Section on Civil and Criminal Tax Penalties
  • American Institute of Certified Public Accountants
  • Texas Society of Certified Public Accountants
  • Dallas CPA Society
    • Tax Committee
  • New York University School of Continuing and Professional Studies
    • Planning Committee Member, 2nd Annual Tax Controversy Forum 
  • UCLA Extension, Business, Management, and Legal Programs
    • Planning Committee Member, 25th Annual Tax Controversy Institute

Past Employment

  • Civil Prosecutor, Internal Revenue Service, Dallas District Counsel office
  • Special Assistant United States Attorney, Department of Justice, Dallas
  • Law Clerk, Honorable Carolyn M. Parr, United States Tax Court, Washington, D.C.

Honors and Awards

  • The Best Lawyers in America©, 2015-2018, Tax Law 
  • 2013 Top Rated Lawyer in White Collar Criminal Defense Law by ALM as published in The American Lawyer, Corporate Counsel & The National Law Journal, October 2013
  • Texas Super Lawyers-Tax as listed in Texas Super Lawyers Magazine and Texas Monthly, 2003 through 2015
  • Best Lawyer Under 40, D Magazine, 2004 and 2005
  • Best Business Lawyers, D Magazine, 2009: Tax 
  • Best Lawyers in Dallas, D Magazine, 2008 and 2011; Taxation: 2012, 2015 and 2016: Tax Litigation

Publications

  • "TEFRA Partnership IRS Controversies: Now That The TEFRA Partnership Exam Is Complete With An FPPA, What Is A Partnership To Do?", Forbes IRS Watch, July 22, 2013
  • "Proposed Schedule Targets Uncertain Tax Positions", In-House Texas, (An ALM Publication), Volume 25, No. 48, March 1, 2010
  • "Government Loses Sham-Transaction Criminal Tax Case in the Virgin Islands", The American Bar Association, Criminal Justice Section Newsletter, Volume 17, Issue 3, Spring 2009
  • “The IRS is Regularly Auditing Taxpayers Again", Dallas Bar Association Headnotes, Volume 32, Number 11, November 1, 2008
  • “The IRS Is Looking For Non-Compliant Taxpayers With Foreign Interests: Is Your Taxpayer One Of Them?”, The Practical Tax Lawyer, Volume 22, Number 3, Spring 2008 (published four times a year by American Law Institute-American Bar Association Continuing Professional Education in cooperation with the ABA Section of Taxation)
  • “Important Tax Controversy Developments”, Texas Tax Lawyer
  • “Voluntary Disclosure and IRS Attacks on Offshore Credit Cards”, Corporate Business Taxation Monthly
  • “When IRS Criminal Special Agents Show up at Your Client's Door", Dallas Bar Association Headnotes, Volume 29, Number 2, March 1, 2005
  • “Foreign Distrust: Cayman Island Crackdown Reveals IRS Concern”, Texas Lawyer
  • “Texas Sales Taxes on Construction-Why Can’t Anybody Get It Right?”, Texas Tax Lawyer

2017 Speaking Engagements

  • East Texas Chapter/TSCPA Spring CE Expo, Tyler – 5/1/17
  • Texas Association of CPAs - Dallas CPE Meeting – 5/4/17
  • Taxation and Estate Planning Update for Professionals Texas Bank and Trust, Tyler – 5/9/17
  • Taxation and Estate Planning Update for Professionals Texas Bank and Trust, Longview – 5/23/17
  • Tax Alliance Conference, Plano – 6/6/17
  • NYU 9th Annual Tax Controversy Forum, New York – 6/15/17
  • Practising Law Institute's (PLI) Basics of International Taxation, New York – 7/18/17
  • 2017 IRS Nationwide Tax Forum Seminars, Dallas – 7/25/17
  • AXA Advisors Seminar, Dallas – 7/26/17
  • 2017 IRS Nationwide Tax Forum Seminars, Dallas – 7/26/17

2016 Speaking Engagements

  • SMU Dedman School of Law – 11/14/16
  • American Bar Association Section of Taxation Webinar – 5/18/16
  • Tax Alliance Conference, Plano – 6/14/16
  • Basics of International Taxation 2016, New York – 7/19/16
  • Basics of International Taxation 2016, San Francisco, CA – 9/19/16
  • 18th Annual Meadows Collier Taxation Conference, Dallas – 10/25/16
  • UT Law 2016 64th Annual Taxation Conference, Austin – 11/30/16
  • ABA 33rd Annual National Institute on Criminal Tax Fraud and the Sixth Annual National Institute on Tax Controversy, Las Vegas, NV - 12/8/16

2015 Speaking Engagements

  • State Bar of Texas Tax Section Leadership Academy, Dallas – 1/15/15
  • Central Texas Chapter/TSCPA CPE Expo, Waco – 5/19/15
  • TSCPA 2015 Nonprofit Organizations Conference – 5/19/15
  • 2015 7th Annual Tax Controversy Forum sponsored by the NYU School of Professional Studies, New York – 6/5/15
  • Practising Law Institute (PLI) Basics of International Taxation 2015, New York
    – 7/21/15 - 7/22/15
  • Practising Law Institute (PLI) Basics of International Taxation 2015, San Francisco – 9/28/15 - 9/29/15
  • 17th Annual Meadows Collier Taxation Conference, Dallas – 11/3/15
  • 32nd Annual National Institute on Criminal Tax Fraud and 5th National Institute on Tax Controversy sponsored by the American Bar Association, Las Vegas – 12/11/15

2014 Speaking Engagements

  • Estate Planning Council of Central Texas, Austin – 4/23/14
  • Texas Bank & Trust Seminar, Tyler – 5/6/14
  • Texas Bank & Trust Seminar, Longview – 5/15/14
  • Central Texas Chapter/TSCPA CPE Expo, Waco – 5/22/14
  • Tax Alliance Conference 2014, Plano – 6/10/14
  • NYU 6th Annual Tax Controversy Forum, New York, NY – 6/20/14
  • Advanced Tax Law Course 2014 sponsored by TexasBarCLE, Dallas – 8/28/14
  • Practice Management Group, Tyler – 10/20/14
  • 16th Annual Meadows Collier Taxation Conference, Dallas – 10/28/14
  • Heart of America Tax Institute, Kansas City, MO – 11/7/14
  • ABA 31st Annual National Institute on Criminal Tax Fraud and the Fourth Annual National Institute on Tax Controversy, Las Vegas, NV – 12/11/14

2013 Speaking Engagements

  • Convergence 2013 sponsored by the Dallas CPA Society, Dallas – 5/8/13
  • NYU 5th Annual Tax Controversy Forum, New York – 6/7/13
  • Tax Alliance Conference 2013, Plano – 6/12/13
  • ACPEN Broadcast - "Doing Business with the IRS", Dallas – 6/19/13
  • 15th Annual Meadows Collier Taxation Conference, Dallas – 10/29/13
  • Webcast, Dallas – 11/6/13
  • Austin Chapter/TSCPA Annual Tax Conference, Austin – 11/19/13
  • WTAS/Barclays, Dallas – 12/10/13

2012 Speaking Engagements

  • East Texas Estate Planning Council, Tyler – 1/4/12
  • Dallas CPA Society, Dallas – 2/9/12
  • Texas Bank and Trust Seminar, Tyler – 5/2/12
  • Texas Bank and Trust Seminar, Longview – 5/8/12
  • Central Texas Chapter/TSCPA CPE Expo, Waco – 5/16/12
  • North American Petroleum Accounting Conference (NAPAC), Dallas – 5/17/12
  • 28th Annual Federal Tax Institute in cooperation with The Texas Institute of Continuing Legal Education, San Antonio – 6/8/12
  • NYU 4th Annual Tax Controversy Forum, New York, NY – 6/15/12
  • TravisWolff In-House Seminar, Dallas – 7/20/12
  • Uptown Exchange Club, Dallas – 8/28/12
  • Leadership Academy, Tax Section of the State Bar of Texas, Austin – 9/21/12
  • Dallas CPA Society's Member Appreciation Series, Dallas – 10/17/12
  • 14th Annual Meadows Collier Taxation Conference, Dallas – 10/30/12
  • Synergy 2012 Conference sponsored by OneSource Products and Thomson Reuters, Grapevine – 11/5 - 11/7/12

2011 Speaking Engagements

  • American Association of Attorneys-Certified Public Accountants, Inc., Dallas – 3/2/11
  • Taxation and Estate Planning Update for Professionals Seminar sponsored by Texas Bank and Trust, Tyler – 5/4/11 and 5/18/11
  • IRS Nationwide 2011 Tax Forum sponsored by the Internal Revenue Service, Dallas – 7/26-28 2011
  • Panhandle Chapter/TSCPA Tax Institute, Amarillo – 8/24/11
  • Texas Bankers Association 2011 Estate Administration Seminar, San Antonio – 9/30/11
  • American Bar Association Section of Taxation and Trust & Estate Division of Real Property Trust & Estate Law 2011 Joint Fall CLE Meeting, Denver, CO – 10/22/11
  • 13th Annual Meadows Collier Taxation Conference, Dallas – 10/25/11
  • 2011 National Tax Meeting - Hein & Associates LLP, Denver, CO – 11/3/11
  • Austin Chapter/TSCPA Annual Tax Conference, Austin – 11/14/11
  • 58th Annual Texas CPA Tax Institute, San Antonio – 11/17/11 and 11/18/11
  • 28th Annual National Institute on Criminal Tax Fraud, Las Vegas, NV – 12/1/11

2010 Speaking Engagements

  • ABA Section of Taxation 2010 Midyear Meeting, San Antonio – 1/23/10
  • Central Texas Estate Planning Council, Austin – 2/23/10
  • Dallas CPA Society Free CPE Day 2010, Dallas – 5/4/10
  • Texas Bank and Trust Annual Taxation and Estate Planning Update for Professionals Seminar, Tyler & Longview – 5/12/10 & 5/26/10
  • Central Texas Chapter/TSCPA CPE Expo, Waco – 5/20/10
  • 28th Annual SBOT Advanced Tax Law Course, Dallas – 8/26/10
  • American Bar Association 2010 Joint Fall CLE Meeting, Section of Taxation, Toronto, Canada – 9/25/10
  • East Texas Estate Planning Council, Tyler – 10/6/10
  • Texas Bankers Association Estate Administration Seminar, Dallas – 10/15/10
  • 12th Annual Meadows Collier Taxation Conference, Dallas – 10/26/10
  • Southwest Practice Management Group, Williamsburg, VA – 11/1/10
  • Austin Chapter/TSCPA Annual Tax Conference, Austin – 11/4/10
  • American Bar Association – National Institute on Criminal Tax Fraud, San Francisco, CA – 12/2/10
  • 2010 TSCPA CPE Expo, Houston & Arlington – 12/6/10 & 12/9/10 

2009 Speaking Engagements

  • Texas Bank and Trust Annual Taxation and Estate Planning Update for Professionals Seminar, Longview & Tyler –  5/20/2009 & 5/27/09
  • Dallas Bar Association Joint Meeting of the Tax & International Sections, Dallas –  7/6/09 
  • 2009 IRS Nationwide Tax Forum sponsored by the Internal Revenue Service, Dallas - 9/8/09 & 9/9/09
  • American Bar Association Tax Section 2009 Joint Fall CLE Meeting, Chicago, IL - 9/26/09
  • East Texas Estate Planning Council, Tyler – 10/1/09
  • DFK/USA Multidiscipline Conference, Fort Worth – 10/21/09
  • 11th Annual Meadows Collier Taxation Conference, Dallas – 10/27/09
  • 2009 Austin CPA Chapter Annual Tax Conference – 11/3/09
© Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P.901 Main Street, Suite 3700, Dallas Texas 75202phone (214) 744-3700 | toll-free (800) 451-0093 | fax (214) 747-3732Hosted on the FirmWise Platform