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Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P.

901 Main Street, Suite 3700
Dallas, TX 75202

Phone: 214.744.3700
Fax: 214.747.3732
Toll Free: 800.451.0093

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Michael A. Villa, Jr.

Mike was named Texas Super Lawyer in Texas Monthly and Texas Super Lawyer Magazines in 2013-2017. In 2010-2013, he was named a Texas Rising Star. Mike focuses on resolving federal tax controversies and white collar crime, including securities, tax and bank fraud.  He represents individuals, closely-held businesses, and large corporations in IRS audits, appeals, and litigation, as well as in business disputes and lawsuits involving fraud, breach of contract, breach of fiduciary duty, deceptive trade practices act violations, non-compete violations, business torts, and other commercial disputes. 

Prior to joining the firm in 2007, Mike worked in Washington, D.C. as a Congressional intern to U.S. Senator John Breaux (Retired) and worked as an Associate with a regional law firm in New Orleans, Louisiana.  In 2004-2005, he served as a Judicial Clerk to the Honorable James J. Brady, U.S. District Court, Middle District of Louisiana.

Mike was admitted to practice in Texas in 2005 and in Louisiana in 2004.

  • New York University School of Law, LL.M. in Taxation, 2007
  • Louisiana State University Paul M. Hebert Law Center, J.D. and Bachelor of Civil Law, 2004
  • Louisiana State University, B.A., 2000
  • American Bar Association
    • Member and Vice Chair ABA Tax, Civil & Criminal Tax Penalties (CCTP) Committee
    • Subcommittee Chair, IRS Investigations & Practices, ABA Tax, Civil & Criminal Tax Penalties (CCTP) Committee
  • State Bar of Texas
    • Co-Chair, Tax Controversy Committee
    • Member, Tax Section, 2017 Annual Meeting Planning Committee
  • Louisiana State Bar Association
  • Dallas Bar Association
  • Dallas Association of Young Lawyers
  • Dallas Bar Foundation
    • Fellow
  • "Feds try to seize dinosaur skull, but doctor says he bought his fair and square", quoted in the August 10, 2017 Dallas Morning News article.
  • Texas Super Lawyers-Tax as listed in Texas Super Lawyers Magazine and Texas Monthly,  2013-2018
  • Texas Rising Stars, as published in Texas Monthly and in Texas Super Lawyers - Rising Stars Edition and on the web at superlawyers.com, 2010--2013
  • Member/Officer, L.S.U. Law Center Moot Court Board
  • Recipient, L.S.U. Law Center Class of 1931 Hebert Memorial Scholarship
  • Recipient, L.S.U. Law Center Gene Hearn Memorial Scholarship
  • Recognized, L.S.U. Law Center Chancellor's List
  • "IRS Criminal Investigation's 2016 Annual Report on Illegal Tax Source Crimes", Journal of Tax Practice and Procedure, April-May 2017
  • "IRS Criminal Investigation Current Initiatives Update", Penalties Column, Journal of Tax Practice and Procedures, June-July 2014.
  • "The Alphabet Soup of Treasury: What in the World are BSA/AML Exams and Who are the Examiners?", BarTabs published by the Collin County Bar Association, May 2012
  • "Recent Trends in IRS Enforcement Activity & Specialized IRS Agents", BarTabs published by the Collin County Bar Association, March 2012
December 14, 2018

2018 Louisiana Tax Conference... [ read ]

December 11, 2018

TSCPA 2018 CPE Expo - Houston... [ read ]

December 4, 2018

TSCPA 2018 CPE Expo - San Antonio... [ read ]

November 30, 2018

TSCPA 2018 CPE Expo - Dallas... [ read ]

October 5, 2018

Federal White Collar Seminar... [ read ]

March 9, 2018

The Federal Bar Association... [ read ]

December 8, 2017

Louisiana Tax Conference... [ read ]

November 7, 2017

First Bank & Trust in Lufkin, TX... [ read ]

September 16, 2017

2017 ABA Tax Section Joint Fall CLE Meeting in Austin, TX... [ read ]

September 7, 2017

TX Society of EAs - DFW Chapter of EA's... [ read ]

August 18, 2017

SBOT Advanced Tax Law Course... [ read ]

June 8, 2017

American Society of Tax Problem Solvers... [ read ]

May 1, 2017

East Texas Chapter/TSCPA Spring CE Expo... [ read ]

December 16, 2016

2016 Louisiana Tax Conference - New Orleans, LA... [ read ]

December 9, 2016

2016 TSCPA CPE Expo- San Antonio... [ read ]

December 6, 2016

2016 TSCPA CPE Expo- Arlington... [ read ]

December 2, 2016

2016 TSCPA CPE Expo- Houston... [ read ]

October 25, 2016

18th Annual Meadows Collier Tax Conference... [ read ]

May 24, 2016

Texas Bank & Trust Seminar- Longview... [ read ]

May 17, 2016

Texas Bank & Trust Seminar- Tyler... [ read ]

May 6, 2016

Texas Association of CPAs... [ read ]

January 30, 2016

ABA Tax Section 2016 Midyear Meeting... [ read ]

January 29, 2016

ABA Tax Section 2016 Midyear Meeting... [ read ]

December 11, 2015

Society of Louisiana CPAs Tax Conference... [ read ]

November 20, 2015

New England IRS Representation Conference... [ read ]

January 15, 2015

"Circular 230: Oversight of the Tax Practitioner" "Hot Topics in IRS Audits and Investigations"... [ read ]

December 19, 2014

"Let's Make a Deal: Federal Income Tax Issues in Purchasing and Selling Businesses, Including Stepped-Up Basis"... [ read ]

December 8, 2014

"Passive Activity and Hobby Loss Limitations: Withstanding an IRS Attack of Your Client's Outside Business Activities Under IRS Sections 469 and 183"... [ read ]

November 21, 2014

"IRS Update: What are They Doing Now?"... [ read ]

April 23, 2014

"Criminal & Civil Aspects of the Bank Secrecy Act"... [ read ]

April 7, 2014

"What to do When CI Knocks on the Door: An Overview of Criminal Tax and Bank Secrecy Act Investigations"... [ read ]

January 23-25, 2014

"Bank Secrecy Act Criminal Investigations" and IRS Investigations and Practices - "Enforcement Update"... [ read ]

November 21, 2013

"How to Manage Criminal Cases When the C.I. Knocks on the Taypayer's Door"... [ read ]

September 21, 2013

"IRS Investigations and Practices" "Department of Justice Tax Division Update"... [ read ]

August 16, 2013

"Ethical Issues Arising in Day-To-Day Tax Practice"... [ read ]

May 11, 2013

"IRS Investigations and Practices Important Developments"... [ read ]

January 26, 2013

"IRS Investigations and Practices Subcommittee Report: Penalty Abatement Procedures & Identity Theft Pilot Program"... [ read ]

December 13-14, 2012

"Tax Litigation: What Is Involved in Taking a Tax Case from Exam to Appeal and When is it Worth it?"... [ read ]

August 15, 2012

"How to Manage Criminal Cases When the C.I. Knocks on the Taxpayer's Door"... [ read ]

May 11, 2012

"Proposed Increased Funding in the Fiscal Year 2013 - Budget Proposal Summary for IRS Enforcement Activities"... [ read ]

October 22, 2011

"Get Ready for the Newest Specialized IRS Civil Agents: The SBSE Fraud/Bank Secrecy Act/Anti-Money Laundering Agent" (Moderator)... [ read ]

May 26, 2011

"Responding to Governmental Inquiries"... [ read ]

May 6-7, 2011

"Recent Trends in IRS Enforcement Activity Regarding Efforts to Increase Collection and Reduce the Tax Gap and Title 31 Anti-Money Laundering Examinations"... [ read ]

January 20-21, 2011

"IRS Investigations and Practices Subcommittee Report: Recent Trends in IRS Enforcement Activity Regarding Structuring and The Bank Secrecy Act ("BSA")" and "Young Lawyers Address Ethical... [ read ]

August 19, 2010

"The Bank Secrecy Act: Currency Reporting Requirements, Related Federal Investigations, and Criminal Prosecutions"... [ read ]

December 14, 2009

"Voluntary Disclosures & Tax Consequences of Ponzi Schemes"... [ read ]

March 21, 2018

Marinello v. United States - Supreme Court Opinion... [ read ]

The U.S. Supreme Court reversed a taxpayer's conviction today under 26 U.S.C. § 7212(a), also known as the Omnibus Clause, which forbids "corruptly or by force or threats of force . . . obstruct[ing] or imped[ing], or endeavor[ing] to obstruct or impede, the due administration of [the Internal Revenue Code]."

July 14, 2017

The RESPECT Act: Will Congress Pass Legislation to Limit IRS Civil Forfeiture in "Structuring" Cases?... [ read ]

The RESPECT Act (H.R. 1843), also known as the Restraining Excessive Seizure of Property through the Exploitation of Civil Asset Forfeiture Tools Act, was originally introduced in the House of Representatives in March 2017. The House Ways and Means Committee recently unanimously approved the RESPECT Act, which prohibits the IRS from carrying out seizures relating to a currency structuring transaction unless the property to be seized is from an illegal source or the funds were structured for the purpose of concealing the violation of another criminal law. It also requires notice and a post-seizure hearing for such currency structuring seizures.

April 6, 2017

The Government Settlement Transparency & Reform Act (S.803): Are the Tax Benefits of Corporate Settlements in Jeopardy?... [ read ]

On April 3, 2017, Senators Jack Reed (D-RI) and Chuck Grassley (R-Iowa) introduced bipartisan legislation that may impact or deny tax deductions for settlement payments regarding corporate regulatory violations. In recent years, the federal government has increased enforcement efforts against corporations for regulatory violations, whether it be for healthcare, banking, or environmental violations. Although the federal government carries a big stick when it comes to regulatory enforcement (i.e. onerous civil fines and potential criminal penalties), there are also carrots that can often facilitate and expedite settlements with corporations.

August 1, 2016

Do You Have an "All Cash" Real Estate Deal in San Antonio or Bexar County, Texas? Additional Government Disclosures May Be Required... [ read ]

The Financial Crimes Enforcement Network (FinCEN) issued a new Geographic Targeting Order (GTO) that requires U.S. title insurance companies to identify the natural persons behind companies used to pay "all cash" for high-end residential real estate in six major metropolitan areas. FinCEN is monitoring whether real estate transactions involving "all cash" (i.e. without bank financing) in deals where the purchasers are limited liability companies, or other business structures that are not transparent, are being used to hide assets related to possible criminal activity.

June 30, 2016

IRS Announces Procedure for Seeking a Return of Property Seized in Legally Sourced Structuring Cases... [ read ]

On June 16, 2016, the IRS announced a new procedure for taxpayers who have had their property seized to file a petition for remission or mitigation. The IRS has identified more than 700 taxpayers that it believes may qualify, and the IRS has been notifying these taxpayers by mail over the past month.

February 26, 2016

Perseverance Pays Off: IRS Returns Seized Cash to Store Owner... [ read ]

Nearly two years ago, Khalid Quran, a convenience store owner in North Carolina, obtained an unwanted firsthand account of the power that the IRS has when seizing funds that it suspects were deposited and/or withdrawn in violation of federal currency reporting requirements. In June 2014, the IRS seized $153,907 from Mr. Quran's business account because he allegedly made several withdrawals of cash under $10,000.

January 20, 2016

Handling Taxpayers Who Have Forgotten Their Filing Obligations... [ read ]

We often encounter clients who have not filed tax returns for many years, some of whom have received a notice from the IRS regarding their non-filing status. Many times, these clients don't have the liquidity or even the assets to pay their delinquent tax obligations and end up applying for an Offer in Compromise (OIC).

October 28, 2015

Federal Agent Steals Virtual Currency and Receives Real World Prison Sentence... [ read ]

On October 19, 2015, a former Drug Enforcement Agent, Carl Force, was sentenced to 78 months in prison for stealing bitcoin related to the federal criminal investigation of Silk Road.

August 28, 2015

TIGTA Report Weighs in on Penalty Abatements... [ read ]

On July 30, 2015, the Treasury Inspector General for Tax Administration ("TIGTA") released a report evaluating whether penalties assessed by the IRS against taxpayers are being abated in accordance with IRS Appeals criteria. The report underscores the need for skilled advocacy when it comes to penalty abatement requests and the importance of ensuring that taxpayers' requests for penalty abatements both comply with the governing standards of penalty relief and contain sufficient information to justify the relief requested.

August 18, 2015

Eleventh Circuit Holds "Cash Hoard" Exceeding $10k Currently is Not Required for a Structuring Indictment... [ read ]

In U.S. v. Sperrazza, the U.S. Eleventh Circuit recently affirmed the conviction of a Georgia physician who was convicted of three counts of tax evasion, in violation of 26 U.S.C. § 7201, and two counts of structuring currency transactions, in violation of 31 U.S.C. § 5324(a)(3). U.S. v. Sperrazza, No. 14-11972 (11th Cir. Aug. 17, 2015).

July 28, 2015

Court Upholds FBAR Penalties, but Rejects Government's Assessed Interest and Late Charges... [ read ]

In Moore v. U.S., No. C13-2063 (W.D. Wash. July 24, 2015), Judge Richard Jones examined a case in which FBAR penalties of $10,000 were assessed for each year from 2005 through 2008. The Court held the IRS's decision to assess the FBAR penalties was not arbitrary, capricious or an abuse of discretion.

July 20, 2015

No Fifth Amendment Protection for Foreign Account Records, Government Prevails in the Third Circuit... [ read ]

On July 17th, a panel for the U.S. Court of Appeals for the Third Circuit held there is no Fifth Amendment protection for foreign bank account records. U.S. v. Chabot, No. 14-4465 (3d Cir. July 17, 2015).

July 13, 2015

Combating the Growing Problem of Tax Fraud and Identity Theft... [ read ]

Identity theft in which a taxpayer's name and tax identification number are stolen and used in order to obtain fraudulent refunds continues to be a growing problem for the IRS and the victim taxpayers.