Jeff Luechtefeld is litigator with a strong technical tax background and a deep understanding of how the Internal Revenue Service operates. Jeff’s practice focuses on resolving tax disputes with the IRS, administratively or through litigation. He regularly represents clients before the United States Tax Court, U.S. District Courts, and in the Circuit Courts of Appeal. In his practice Jeff places significant emphasis on the interplay between administrative law and tax law in defending his client’s tax positions; for example, Jeff has successfully argued that the Tax Court should reverse prior precedent and hold a treasury regulation procedurally invalid under the Administrative Procedure Act (APA).
Jeff also has significant experience advocating for his client’s positions in IRS examinations and before the IRS Independent Office of Appeals. His knowledge of the innerworkings of the IRS, combined with strong strategic thinking and negotiation skills, allows him to effectively advocate for his clients. Jeff’s diverse client base has included Fortune listed companies, professional sports franchises, private equity firms, closely held businesses and high-net-worth individuals. He also represents clients in areas of significant IRS enforcement focus, such as syndicated conservation easement transactions and micro-captive insurance arrangements. Jeff has assisted clients in a wide range of substantive matters, including complex partnership issues; repairs regulations disputes; Section 197 intangible amortization; foreign tax credit issues; bad debt and worthless stock deductions; accounting method changes; compensation-related issues; and claims for research credit and domestic production deductions.
Previously, Jeff led the regional tax controversy practice for a big four accounting firm, where he assisted clients in resolving disputes administratively within the IRS, either while still in examination or in appeals. Jeff began his career with the IRS Office of Chief Counsel as a litigator and was eventually appointed as a special trial attorney in the Large Business and International Division, where he was responsible for advancing some of the most important, sensitive, and complex cases before the Tax Court. His prior experience representing the IRS in tax cases has included matters involving variable prepaid forward contracts; Subpart F income; characterization issues related to aircraft (including passive activity limitations and questions of personal use); and conservation and façade easement transactions (including complex valuation issues).