Joel N. Crouch

• The Best Lawyers in America® Lawyer of the Year in Dallas/Ft. Worth for Tax Law 2022
• The Best Lawyers in America® for Litigation and Controversy – Tax and Tax Law, 2015-2026
• 2013 Top Rated Lawyer by ALM, The American Lawyer, Corporate Counsel & The National Law Journal for White Collar Criminal Defense Law, October 2013
• Texas Super Lawyers,Texas Super Lawyers and Texas Monthly for Tax, 2003-2025, 2020, 2024, and 2025 Texas Super Lawyers Top 100, Dallas/Ft. Worth
• Best Lawyers in Dallas, D Magazine for Tax General 2012-2023 and Tax: Litigation 2024-2026
• Band 2 Ranked, Chambers and Partners, USA for Tax: Litigation, 2024-2026

Representative Cases

Civil Tax Controversies Representation Matters

• Client in appeal to the U.S. Supreme Court regarding the IRS attempt to invoke a six year statute of limitations.
• Client in an appeal to the U.S. Fifth Circuit regarding the IRS attempt to impose a substantial penalty.
• Client in an appeal to the U.S. Fifth Circuit and successfully argued that the IRS cannot invoke a six year statute of limitations.
• Client in a successful challenge to the IRS’ attempt to retroactively apply a Treasury regulation.
• Client in successfully resolving issues regarding unfiled payroll tax returns for multiple years.
• Numerous clients through the IRS Offshore Voluntary Disclosure initiatives and other voluntary disclosure programs.
• Family in challenge to IRS disallowance of tax benefits and prepared imposition of penalties.
• 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.
• Client in IRS challenge to losses arising from investment in distressed assets.
• Attorney in a challenge to IRS summons for records related to attorney’s client’s offshore activities.
• Numerous clients in tax shelter examinations and civil litigation.
• Clients in IRS attempt to reclassify losses associated with horse and cattle activities as hobby losses under IRC § 183.
• Clients in IRS challenges to classification of independent contractors versus employees.
• Numerous tax professionals under investigation for alleged ethical and IRS Circular 230 violations.
• Large public company in an IRS challenge to deduction of expenses related to merger with competitor.
• Owner and closely-held business in IRS examination of issues related to change in accounting method.
• Client in IRS attempt to impose penalties during litigation of civil tax matter.  Successfully convinced court that the government could not propose penalties.
• Client in connection with IRS challenge to losses arising from failed tender offer for a foreign publicly-traded company.
• Numerous estates in IRS challenges to the valuation of closely-held businesses and estate planning vehicles fractionalizing ownership and control.
• 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

• CPA subject of an investigation by the Tax Inspector General’s Office and negotiated a resolution involving no criminal charges.
• Numerous clients in making voluntary disclosures to the IRS regarding unfiled tax returns, substantiation tax issues and offshore activities to avoid criminal prosecution.
• Large National Corporation in investigation of potential environmental criminal violations.  Convinced the government that no criminal charges should be brought.
• An attorney in an IRS investigation of failure to file tax returns.
• A hospital chain in a healthcare fraud investigation following the execution of search warrants based on allegations made by a qui tax relation.
• 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.
• A banker indicted for allegedly failing to disclose relationship to borrowers who later defaulted on loan.  The client was acquitted on all counts.
• 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.

• “6 Keys to Avoiding Section 6701 Penalties”, The Value Examiner, May/June 2006 Issue, National Association of Certified Valuation Analysts
• “Take Two: IRS Voluntary Disclosures and The Offshore Disclosure Initiatives”, April 2011 Issue of BarTabs published by the Collin County Bar Association
• “Avoiding Criminal Tax Problems: Voluntary Disclosure”, Originally published in Headnotes, Vol. 36, No. 5, May 1, 2011, page 9 (published monthly by the Dallas Bar Association)
• “Is Three Times a Charm? The IRS Announces a Third Offshore Voluntary Disclosure Initiative”, February 2012 Issue of BarTabs published by the Collin Country Bar Association
• Mr. Crouch was quoted in the Tax Analysts article, “Kollsman Case Offers Cautionary Tale for Art Appraisals.”