Attorney & Founder
Jeff Rice
Former IRS attorney
For more than thirteen years, Jeff represented the government in federal tax matters. He now represents taxpayers in tax controversy — the same procedures, from the other side of the table.
13
Years as an IRS attorney
LL.M.
Taxation, Georgetown
U.S.
Tax Court admitted
Focused on
Tax controversy
Inside the agency
Jeff spent over thirteen years as an attorney for the Internal Revenue Service. That is not a line on a résumé so much as a working education in how the agency actually decides things: how a case gets selected, how an examiner develops it, what a revenue officer is authorized to do and what merely sounds like authority, and how Appeals officers weigh the hazards of taking a case to trial.
Most taxpayers experience the IRS as a wall of correspondence. From the inside, it is a set of procedures with rules, deadlines, internal guidance, and a great deal of discretion exercised by individual people. Knowing where that discretion sits, and what actually moves it, is the difference between a case that resolves and one that grinds.
The government’s position often sounds more settled in the notice than it is in the file.
After leaving the IRS, Jeff worked in private practice at a national professional services firm and at a boutique tax litigation firm before founding Rice Tax Law PLLC. He has represented individuals, businesses, estates, and organizations at every stage of a tax dispute — from the first examination letter through IRS Appeals and, when necessary, into the United States Tax Court.
Education
- LL.M. in Taxation, with distinction — Georgetown University Law Center
- Juris Doctor, cum laude — Case Western Reserve University School of Law
Admissions & memberships
- Washington State Bar Association — Licensed to practice law in Washington
- United States Tax Court — Admitted to practice before the court
- American Society of Tax Problem Solvers — Member
Experience
Representative matters
The kinds of federal tax disputes this firm handles. Every matter is different, and the list below describes categories of work rather than any particular case.
EXAMINATION
Individual audits
Examinations involving equity compensation, cost basis reporting, self-employment income, and substantiation of deductions.
EXAMINATION
Business audits
Schedule C, partnership, and corporate examinations, including recordkeeping disputes and reconstruction of incomplete books.
EMPLOYMENT TAX
Trust Fund Recovery
Defense of penalties assessed personally against owners and officers for unpaid payroll taxes, and worker classification disputes.
COLLECTION
Liens and levies
Collection Due Process hearings, Offers in Compromise, installment agreements, and Currently Not Collectible status.
LITIGATION
Tax Court petitions
Deficiency cases from petition through pretrial development, settlement negotiation, and trial where a case does not resolve.
INTERNATIONAL
Offshore compliance
FBAR and FATCA reporting, streamlined filing procedures, and voluntary disclosures for accounts held outside the United States.
PENALTIES
Abatement and relief
Reasonable cause arguments, first-time abatement, and Appeals of penalty determinations that exceed the underlying tax.
RELIEF
Innocent spouse
Requests for relief from joint liability where one spouse had no knowledge of or benefit from the understatement.
ESTATES
Fiduciary matters
Examinations and collection matters involving estates, trusts, and the unpaid tax obligations of a decedent.
WASHINGTON
Department of Revenue
State excise and B&O tax audits, assessments, and administrative appeals before the Washington Department of Revenue.
The descriptions above identify types of matters handled. They are not descriptions of results, and prior experience does not guarantee a similar outcome in any case.
How the firm works
Matters at Rice Tax Law PLLC are handled by an attorney. Analysis, strategy, and every communication with the IRS come from someone licensed to give legal advice — not from unlicensed case staff working from a script, which is how much of the tax relief industry operates.
Fee structure depends on the matter. Many defined engagements are handled on a flat fee, quoted in writing early in the representation, so the cost is known rather than accumulating on an hourly meter during a stressful year.
Matters can be handled entirely remotely when that suits the client, and in-person meetings are available as well. Either way, clients can be represented wherever they are. Admission to the United States Tax Court permits representation in federal tax matters nationwide.
The practice is built around tax controversy, and that is where nearly all of the work is. A limited amount of planning and return preparation is accepted as well, generally for clients already working with the firm on a controversy matter.
If your notice has a date on it, start now.
Send a general description of your situation. Please do not include Social Security numbers, account numbers, or documents in a first message.