Junior Tax Attorney

Jr. Tax Attorney - Job Ad

Join our prestigious tax law firm, which has been recognized as an award-winning firm in the Union Tribune’s BEST of SD! Our high-powered team of tax attorneys and legal professionals relentlessly defend businesses in government tax audits to keep companies in business. Our team are distinguished professionals whose background include former business owners, key executives, and government employees. Most of our clients are referred by other attorneys and CPAs, which speaks to our extraordinary results and great working relationships. 

As a member of our cohesive team, you will actively contribute to defend businesses scrutinized by IRS and State of California in tax audits and tax collection matters. Your role will be critical in analyzing a company’s financial records for domestic and international business transactions and working with our team to develop sound defenses in tax law to challenge IRS and State of California tax investigations. 

If you are driven and intellectually curious, have a high-sense of urgency, thrive on working on high-stakes cases with minimal hierarchy, and confident to embrace new challenges, please read on… 

Regardless of what role you perform, everyone at our firm is equally important. Each person who is selected to work at Milikowsky Tax Law has unique legal and business expertise and is driven to succeed. Our collaborative firm culture demands that each team member always contributes their best work product and relentlessly drives a result for our clients. Our firm understands the benefit of working together as a team. 

Keep Reading IF: 

YOU UNDERSTAND HOW A BUSINESS IS RUN. You have a broad knowledge of business operations and can identify tax issues in various business transactions. You also understand the implication of tax law applied to a particular transaction. 

YOU NATURALLY INSTILL TRUST. You have proven communication skills (verbal and written) that make clients comfortable with you and trust your well-thought out advice. You also have an ability to clearly and effectively communicate the client’s position to the government to persuasively negotiate a resolution with the government that protects the client’s interest. You are also able to craft impromptu legal arguments during a meeting with the government, or in court, when faced with a challenge. 

You have the ability to interject humor, personal stories and anecdotes into client discussions to simplify complex issues and minimize the client’s anxiety. 

QUALITY, DETAILS AND FOLLOW-THROUGH MATTER TO YOU. You take pride and ownership in the quality of your work product and you are intensely precise and thorough. You have a proven track-record of following-through on client matters, tasks, and deadlines to complete an objective in a timely manner. It is your nature to consistently communicate with your team (other attorneys and support staff) to ensure all team members are actively working together to complete each client’s matter with an effective and successful outcome. 

YOU ARE A CRITICAL THINKER. You enjoy diving deep into issues and identifying and developing multiple points of view. You enjoy the challenge of reviewing, analyzing, and interpreting complex tax laws and challenging business transactions to discover the meaning behind the numbers. 

YOU HAVE A POSITIVE SENSE OF URGENCY. You maintain a positive disposition, even if you are under a tight deadline and pressures. You have a sense of professionalism and personalism that keeps the clients and team happy in the work process. You are able to handle stress effectively to keep focused on the task without being overwhelmed by deadlines or volumes of information. You can also diffuse tense situations. 

Essential Job Functions will likely include: 

Attorney will be responsible for reviewing financial business and tax records, researching domestic and international tax matters, and developing a strategy to resolve current and future legal tax disputes with federal and state tax agencies. Case load will include civil and criminal tax matters.

·       Defend companies in civil audits and criminal investigations by IRS and State of California tax agencies relating to income tax, misclassification of workers as independent contractors, sales tax, and business property tax;

·       Monitor Federal and California legislative and case law developments to advise clients on the impact on their business transactions and risk of a government examination;

·       Analyze and interpret business financial records (P&L, Balance Sheet, General Ledger, invoices, bank statements) to establish facts through data analytics and identify key issues reported on a business tax return to accurately assess the risk of a civil tax assessment and possible criminal investigation;

·       Research federal and California State tax laws on novel issues to advise clients to minimize the risk of a future government examination or reduce potential adjustments by the government on a tax return.

·       Draft legal memoranda to clients and CPAs and correspondence to IRS and California State tax agencies that clearly and concisely articulates a client’s legal position and effectively presents legal arguments to resolve an audit or criminal investigation;

·       Investigate companies and information available through alternative resources used to substantiate a legal position on a tax return;

·       Use effective oral advocacy to litigate cases in United States Tax Court and resolve matters through the administrative process in IRS Appeals.

·       Successfully resolve tax balances with IRS and California State tax agencies after thoroughly interviewing clients and reviewing financial records. Develop strategies to resolve a tax balance through an offer in compromise, installment agreement, or possible Currently Not Collectible status.

·       Work with our sophisticated team of tax attorneys and professionals to develop a strategy through brain-storming sessions after completing tax research and financial analysis.

·       Work with CPAs to properly report business transaction that may have uncertain legal positions. 

Education, Skills & Experience REQUIRED: 

The ideal candidate for this opportunity has a detailed knowledge of tax laws coupled with some business and accounting experience and solid math skills, excellent ability to effectively advocate for clients through oral and written communication, and solid analytical and critical thinking skills.

·       Along with a JD and active California Bar license, you must have tax controversy experience. Must also have some experience working in business operations and reviewing and interpreting financial records. Must some working knowledge of accounting. LLM, CPA is preferred.

·       3 years’ experience routinely working with federal and State of California tax controversy matters including independently defending companies in examinations, resolving income tax and payroll balances over $100k, defending clients in TFRP interviews, releasing bank levies and liens, and negotiating OICs and IAs.

·       3 years’ experience in drafting correspondence to IRS or State of California tax agencies, which includes drafting Protest Letters, Petitions for Redeterminations, Audit Reconsiderations, letters summarizing financials in support of an OIC or IA, preparing legal memoranda and client letters opining on a current or future business transaction. Some publishing of articles and speaking engagements a plus.

·       Intermediate-advanced experience working with excel to input, analyzing, and summarize large amounts of financial data with formulas.

·       Detail-Oriented, ability to prioritize and always meet internal and external deadlines.

·       Experience working on a team with other attorneys and legal staff to complete a client matter or task.

·       Advanced Microsoft Outlook skills for scheduling, e-mail and task management.

·       Excellent computer and organizational skills.

·       Strong analytical, written and verbal communication skills.

·       Some legal experience with civil litigation and/or bankruptcy preferred.

Milikowsky Tax Law offers a competitive compensation package, including healthcare, 401k, bonus potential based on performance metrics, annual firm retreats including team building events, a beautiful office space in Encinitas within 3 blocks of the beach and the opportunity to work amongst a talented team of tax attorneys and professionals who are passionate about producing great results.