Josh O. Ungerman

•  Lawdragon 500 Leading Global Tax Lawyers for Tax Controversy and Litigation, 2025-2026
• Texas Super Lawyers, Texas Super Lawyers Magazine and Texas Monthly for Tax, 2003-2025
• Texas Super Lawyers, Top 100 Lawyers in Texas, 2017
• The Best Lawyers in America®  “Lawyer of the Year” in the Dallas/Fort Worth for Litigation and Controversy – Tax and Tax Law, 2023
• 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
• Best Lawyers, D Magazine‘s Hall of Fame for Tax: Litigation, 2022
• Best Lawyers in Dallas, D Magazine, for Taxation,  2008, 2011 and Tax: Litigation, 2012, 2015-2016 and 2018-2026
• Best Business Lawyers, D Magazine for Tax 2009
• Best Lawyer Under 40, D Magazine, 2004-2005
• Five-year appointment to the American Bar Association Section of Taxation’s Committee on Appointments to the Tax Court ending June 30, 2023
• Ranked Band 3, Chambers and Partners, USA for Tax: Litigation, 2008-2016, 2024-2026

• 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.

Quotes:

• Mr. Ungerman was quoted in the Wall Street Journal articled published on March 29, 2024 by Laura Saunders titled, “How a ‘Gorgeous’ Dior Bag Cost a Widow $61,000 in Tax Court.”
• Mr. Ungerman was quoted in the Bloombrg Law article published on February 28, 2024 by Chris Cioffi titled, “IRS Chief Counsel Nominee Heading to Senate Nod, Big Tasks Ahead.”
• Mr Ungerman was quoted in the Bloomberg article, “HiLL TAX BRIEFING: Taxes in Focus Heading Into First 2020 Debate,” by Colin Wilhelm, Kaustuv Basu and Patrick Ambrosio on September 29, 2020.
• Mr. Ungerman was quoted in the Tax Analysts article, “Taxpayers’ FBAR Fifth Amendment Gambit Fails,” by Andrew Velarde on September 16, 2020.
• Mr. Ungerman is quoted in the TaxNotes article, “Appraiser Accuses IRS, DOJ of Violating Taxpayer Privacy Rules,” by Kristen A. Parillo on December 30, 2019.
• Mr. Ungerman is quoted in the Tax Analysts article, “Practitioners See Potholes on Rettig’s Road to Sentencing Court,” by Nathan J. Richman on November 13, 2019.
• Mr. Ungerman is quoted in the TaxNotes article, “First Charges Announced for Bad Entry Into OVDP Alternative,” by Nathan Richman on August 28, 2019.
• Mr. Ungerman is quoted in the TaxNotes article, “Stakes Rising in Litigation of Non-Willful FBAR Violations,” by Andrew Velarde on August 1, 2019.
• Mr. Ungerman is cited in The 9th Circuit on opinion in Altera Corporation, The White Paper: The Stealth Bomber of the Section 482 Arsenal, 42 Sw. L.J. 1107, 1128-29 (1989) on June 7, 2019.
• Mr. Ungerman is quoted in the Wall Street Journal article, “The $26 Million Question: What Happens if You Don’t File Your Taxes for a Decade?,” by Laura Saunders on April 5, 2019.
• Mr. Ungerman is quoted in the Tax Analysts article, “More Marinello Uncertainties Rising to the Surface,” by Nathan J. Richman on March 1, 2019.
• Mr. Ungerman is quoted in the Bluebook article, “Federal Court Upholds Maximum Penalty for Willful FBAR Violation,” by Ryan Finley on January 3, 2019.
• Mr. Ungerman is quoted in the article, “Tax Cheats Face Higher Penalty for Hiding Assets From IRS,” by Siri Bulusu on December 6, 2018.
• Mr. Ungerman is quoted in the article, “Palantir Deal May make IRS ‘Big Brother-ish’ While Chasing Cheats,” by Siri Bulusu on December 6, 2018.
• Mr. Ungerman is quoted in the TaxNotes article, “Constructive Knowledge Not Enough for FBAR Willfulness,” by Andrew Velarde on September 11, 2018.
• Mr. Ungerman is quoted in the TaxNotes article, “Court Finds FBAR Penalty Can Exceed $100,000,” by Kristen Parillo on September 11, 2018.
• Mr. Ungerman is quoted in the TaxNotes article, “IRS Using Data Analytics and New Unit to Sift 1 Billion Records,” by Nathan Richman on June 26, 2018.
• Mr. Ungerman is quoted in the Bloomberg Law article, “Pharma CEO ‘Reckless’ in Not Disclosing Swiss Account: Government,” by Matthew Beddingfield on April 27, 2018.
• Mr. Ungerman is quoted in the TaxNotes article,“Taxation of Bitcoin, Its Progeny, and Derivatives: Coin Ex Machina,” by Stevie Conlon, Anna Vayer and Robert Schwaba on February 19, 2018.
• Mr. Ungerman is quoted in the TaxNotes article,“Kim Sentence Leaves Questions About FBAR Guideline Shift,” by Nathan Richman on February 12, 2018.
• Mr. Ungerman is quoted in the TaxNotes article,“FOIA Request Nets Six More OVDP CHIEF Counsel Memos,” by Andrew Velarde on January 23, 2018.
• Mr. Ungerman is quoted in the TaxNotes article,“Judge Vastly Narrows Summons on Coinbase Bitcoin Exchange Users,” by Emily Foster on December 1, 2017.
• Mr. Ungerman is quoted in the TaxNotes article,“FOIA Request Yields 3 OVDP CHIEF Counsel Memos,” by Andrew Velarde on November 21, 2017.
• Mr. Ungerman is quoted in the TaxNotes article,“IRS Involvement in Mueller Probe May Not Be About Taxes,” by Nathan Richman on September 11, 2017.
• Mr. Ungerman is quoted in the TaxNotes artilce, “Are Public Leaks Enough for the Higher U.S. OVDP Penalty?,” by Nathan Richman on August 21, 2017.
• Mr. Ungerman is quoted in BNA’s Daily Tax Report article, “Swiss Firm’s Tax Pact Signal to U.S. Clients Hiding Money Abroad, White Collar Crime Report,” by Alison Bennett on August 18, 2017.
• Mr. Ungerman is quoted in the TaxNotes article, “Manafort Raid Could Indicate Suspected FBAR Violations,” by Stephanie Cumings on August 10, 2017.
  
• Mr. Ungerman is quoted in Tax Notes Today by Tax Analysts article, “Fairness and Transparency Still Problems for OVDP,” by Andrew Velarde on January 15, 2015.
• Mr. Ungerman is quoted in a BNA Daily Tax Report article, “Julius Baer Decision Offers Little Safety For Hidden Swiss Accounts, Attorneys Say,” by Alison Bennett and Daniel Pruzin on January 16, 2014.
• Mr. Ungerman is quoted in a BNA Daily Tax Report article, “Swiss Banks Under Pressure as Deadline Nears for DOJ Program to Find U.S. Accounts,” by Alison Bennett on December 20, 2013.
• Mr. Ungerman is quoted in TaxNotes by Tax Analysts article, “Second Circuit Reverses Convictions of 2 Former E&Y Shelter Promoters,”  on November 30, 2012.
• Mr. Ungerman is quoted in Tax Notes by Tax Analysts article, “The IRS’s Misguided Fraud Whodunit,” by Jeremiah Coderon on October 1, 2012.
• Mr. Ungerman is quoted in the Daily Tax Report article, “Hackers Offering Romney’s Tax Returns Face Serious Punishment if Caught,” by William Hoffman on September 7, 2012.
• Mr. Ungerman is quoted in BNA’s Daily Tax Report in an article titled, “Taxpayers Fear Disclosing Offshore Assets As Deadline Approaches, Practitioners Say,” on August 15, 2011.
• Mr. Ungerman is quoted in TaxNotes by Tax Analysts article, “Applying Mayo, Federal Circuit Defers to Controversial Overstated Basis Regulation,” by Jeremiah Coder on March 14, 2011.
• Mr. Ungerman is quoted in TaxNotes by Tax Analysts article, “Seventh Circuit Overturns Tax Court on Gross Income Omission,” by Jeremiah Coder on January 31, 2011.
• Mr. Ungerman is quoted in the BNA Daily Tax Report, “IRS Withdraws ‘John Doe’ Summons Against UBS Over Tax Fraud Allegations,” by Daniel Pruzin (Geneva) and Alison Bennett (Washington) on November 17, 2010.
• Mr. Ungerman is quoted in a Tax Practice article published by Tax Analysts, “IRS Undeterred After Tax Court’s Intermountain Decision,”  on May 24, 2010.
  
• Mr. Ungerman is quoted in a Tax Practice article published by Tax Analysts, “IRS Help for Struggling Taxpayers Contrasts With Enforcement Push,” on April 12, 2010,
• Mr. Ungerman is quoted in a Tax Practice article published by Tax Analysts, “Federal Circuit Overturns Penalty Determination in Jade Trading,” on  April 5, 2010.
• Mr. Ungerman is also quoted in an article published on Tax Analyst entitled, “Swiss Agree to Expedite Processing of 4,450 UBS Accounts Under Treaty Request,” by David D. Stewart on August 20, 2009.
• Mr. Ungerman is quoted in the Bloomberg article, “Billionaire Tax Felon Says UBS Lied in Pledge to Report to IRS,” by David Voreacos on June 9, 2009.
• Mr. Ungerman is quoted 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.

Articles:

• “Being Prepared for an IRS Criminal Investigation Visit”, Dallas Bar Association Headnotes, April 2023
• Mr. Ungerman published the article, “IRS Criminal Investigation 2017 Annual Business Report—Criminals Would Be Foolish to Mistake Declining Resources for a Lack of CI Commitment,” 20 JOURNAL OF TAX PRACTICE & PROCEDURE 31–36 (August-September 2018).
• 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 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. “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.
• 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 Jourrnal published by the Institute of Pertoleum Accounting at the University of North Texas.
• Alan K. Davis and Josh O. Ungerman published an article, “An Untaxing Year” in the December 20, 2010 Texas Lawyer, Vol. 26., No. 38.
• “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.