Civil Tax Controversy
(Federal & Washington State)
Legal Assistant: Nate Hawthorne
Rich Johnson represents businesses and individuals in disputes with the Internal Revenue Service and the Washington State Department of Revenue.
Rich joined LeSourd & Patten, P.S. in 2006 after graduating cum laude from Seattle University School of Law in Seattle, Washington. While at Seattle University, he focused on tax law and interned with the IRS Office of Chief Counsel, where he assisted in a variety of civil tax controversy cases. Rich completed his LL.M. degree in taxation at the University of Washington School of Law.
On top of his practice, Rich teaches courses in federal tax procedure and federal estate & gift tax in the Master of Professional Accounting (MPAcc) program at the University of Washington, Michael G. Foster School of Business.
His recent cases include, but are not limited to:
- protesting IRS audit determinations
- protesting Washington State Department of Revenue (DOR) audit determinations for in-state and out-of-state taxpayers (including business & occupation tax, sales tax, use tax, cigarette & tobacco taxes); including representing taxpayers accused of using sales suppression (zapper) sofware
- challenging federal trust fund recovery penalty assessments (unpaid federal employment taxes)
- appealing Washington DOR trust fund accountability assessments (collected and unpaid sales tax)
- representing tax return preparers in protesting return preparer penalties
- general tax collection matters such as penalty abatement, offers in compromise, installment agreements, and resolving lien, levy, and garnishment issues.
- University of Washington School of Law, LL.M. (Taxation), 2009
- Seattle University School of Law, J.D., cum laude, 2006
- Whitman College, B.A., Economics & Chemistry-Biology
Presentations & Publications
Rich speaks to professional groups about tax controversy (IRS & DOR audits and collection) matters. Some of his more recent presentations include:
- The IRS Audit Process, Washington State Tax Consultants
- DOR Audits of Contractors and the Documents Needed to Survive, Lorman Sales and Use Tax for Contractors Seminar
- An Introduction to Representation: Collection Cases, Washington State Tax Consultants
- Dealing with the DOR: Audits & Collection, Lorman Sales & Use Tax Seminar
- IRS Income Tax Audits & Appeals – The Highlights, WSCPA, South King County Chapter
- Washington State Bar Association, Tax Section
- Washington State
- United States Tax Court
- United States District Court for the Western District of Washington
- United States Court of Appeals for the Ninth Circuit
- The Best Lawyers in America, Tax Law (2010-2016)
- Super Lawyers Rising Star, Tax Law (2011-2016)