Tax Attorney Ronald Hood Tax Litigation Trial Experience
During his career with the IRS Office of Chief Counsel, Attorney Hood litigated complex tax issues as well as straightforward tax issues such as unreported income and civil fraud. Attorney Hood had more than forty (40) of his cases go to trial in the U.S. Tax Court, of which fifteen (15) cases are reported U.S. Tax Court decisions.
From his experience as a government litigator, Attorney Hood found that the IRS would prefer to settle cases instead of litigating the cases in the U.S. Tax Court. However, in the cases that the government does take to trial in the U.S. Tax Court, the U.S. Tax Court rules in the government's favor more than half of the time. As a government litigator, Attorney Hood's analytical skills in investigating and determining the relevant and material facts of each case and applying those facts to the applicable law, made him a very successful litigator, as evidenced by the favorable decisions of the U.S. Tax Court involving his cases. Please see the list of representative cases below.
If you have any questions about litigation in U.S. Tax Court, contact Ronald F. Hood, former IRS tax attorney at my Cape Cod law firm for a free initial consultation.
Settlement vs. Trial
Litigation for a taxpayer is costly and time consuming. The IRS Appeals Office is the place where a taxpayer can achieve the best results in settling cases. The sole function of the IRS Appeals Office is to resolve tax disputes so that litigation can be avoided. If every case went to trial, there wouldn't be enough IRS attorneys to handle the trial dockets. Cases are settled based on the hazards of litigation which is more or less an analysis by the Appeals Officer of what he or she believes is the percentage risk of going to trial and the government being the prevailing party.
Since being in private practice for nine (9) years, after spending twenty-five (25) years as an IRS trial attorney, Attorney Hood has been able to achieve favorable settlements for his clients' cases that were in the jurisdiction of the U.S. Tax Court but were settled with the IRS prior to trial. Currently, Attorney Hood has several cases under the jurisdiction of the U.S. Tax Court that are in the pre-trial stage.
Pescosolido v. Commissioner, 91 T.C. No.6
Dartmouth Clubs Inc. v. Commissioner, T.C. Memo 2000-167
Allen v. Commissioner, T.C. Memo 1999-385
London v. Commissioner, T.C. Memo 1998-346
Olbres v. Commissioner, T.C. Memo 1997-437
Bennett v. Commissioner, T.C. Memo 1997-145
Johnson v. Commissioner, T.C. Memo 1991-645
Sotiros v. Commissioner, T.C. Memo 1991-95
Caruana v. Commissioner, T.C. Memo 1989-371
Cosentino v. Commissioner, T.C. Memo 1989-305