General Attorney (Tax) (Senior Counsel)

Closing Date: 3rd April, 2024

Description:

Summary:
Office of Chief Counsel, IRS, seeks enthusiastic individuals to serve taxpayers fairly and with integrity by providing correct and impartial interpretation of the internal revenue laws and the highest quality legal advice and representation for the IRS. Please click "Learn more about this agency" to find out more about Chief Counsel's various offices, to view some of the workplace attributes that Chief Counsel's workforce rates most favorably, and to hear from employees themselves.

Duties:
The Office of Division Counsel, Large Business and International (LB&I) is headquartered in Washington, DC and has five Area Counsels located in Manhattan, NY; Newark, NJ; Chicago, IL; Dallas, TX; and San Francisco, CA. Each Area Counsel is responsible for legal work within a defined geographic group. Large Business and International provides legal services to the LB&I Division of the Internal Revenue Service. Our taxpayers are corporations, subchapter S corporations, and partnerships with substantial assets. We work with complicated issues of tax law and accounting principles in the context of an expanding global environment. LB&I employs over 380 attorneys nationwide, who provide a full range of legal services on all issues, including advising LB&I compliance agents, handling litigation in the U.S. Tax Court, and referring and recommending litigation to the Department of Justice.

As a General Attorney (Tax) (Senior Counsel), you will:

• Provide technical written legal advice on some of the Office's most complex, important, or novel trial/case/project assignments, particularly those with broad impact or potentially controversial ramifications. Provide legal services and strategies on tax matters that involve corporations, subchapter S corporations, partnerships, and individuals with substantial assets and complicated legal and accounting issues in the context of an expanding global environment. As delegated by the manager, plan, develop, and complete complex legal work products without review and provide technical guidance and review of staff work products.
• Serve as lead attorney or team member with responsibility for all facets of litigation before the United States Tax Court. This responsibility includes the development and trial of docketed cases including discovery, pretrial motions, stipulations of fact, trial, trial memoranda, and briefs or the review thereof. Work with Department of Justice on complex refund litigation and other litigation matters.
• Use knowledge of the United States Tax Court Rules of Practice and Procedure and Federal Rules of Civil Procedure related to Discovery and e-Discovery to litigate effectively cases in the United States Tax Court. This includes using litigation technology database review tools to organize, analyze, and retrieve case data for discovery and trial preparation and using trial litigation software to litigate cases.
• Exercise signatory authority on own work and work of others, under the relevant delegated authority. Apply a high level of sophisticated analysis and research to identify and assess approaches. Make recommendations on behalf of the Office to executives and managers. Interact with personnel from other LB&I Division Counsel offices, other Counsel Divisions, IRS, Department of Treasury, Department of Justice, other Federal agencies, taxpayer's representatives, petitioner's counsel, and/or others on behalf of LB&I to exchange information or coordinate actions to handle and complete assignments. Serve as a tax expert on matters dealing with specialized taxpayer and industry groups.
• Serve as team leader on large-scale LB&I guidance projects, publications, and litigation matters that may include representatives from other LB&I Division Counsel offices, other Counsel Divisions, or IRS. Direct and coordinates work of other team members and oversee all related administrative and logistical matters.
• This is not an all-inclusive list.

Requirements:
Conditions of Employment:

• Refer to "Additional Information"
• Click "Print Preview" to review the entire announcement before applying.
• Must be a U.S. Citizen or National

Qualifications:
In order to qualify, you must meet the education and/or experience requirements described below. Your resume must clearly describe your relevant experience; if qualifying based on education, your transcripts will be required as part of your application.

To qualify for this position of General Attorney (Tax) (Senior Counsel), you must meet the qualification requirements listed below by the closing of this announcement:

• Possess at least the first professional law degree (LL.B. or J.D.) from a law school accredited by the American Bar Association; AND
• Applicants must be an active member in good standing of the bar of a State, U.S. Commonwealth, U.S. territory, the District of Columbia, or the Commonwealth of Puerto Rico;

• 1 year of general professional legal experience from any area of expertise; plus
• 3 year(s) of professional legal tax experience

Education Substitution: An LL.M. degree in Taxation/Tax Law may be substituted for the one year of the general legal experience listed above.

Experience refers to paid and unpaid experience, including volunteer work done through National Service programs (e.g., Peace Corps, AmeriCorps) and other organizations (e.g., professional; philanthropic; religious; spiritual; community; student; social). You will receive credit for all qualifying experience, including volunteer experience. One year of experience refers to full-time work; part-time work is considered on a prorated basis. To ensure full credit for your work experience, please indicate dates of employment by month/year, and indicate number of hours worked per week, on your resume.

Education:
For positions with an education requirement, or if you are qualifying for this position by substituting education or training for experience, submit a copy of your transcripts or equivalent. An official transcript will be required if you are selected.

A college or university degree generally must be from an accredited (or pre-accredited) college or university recognized by the U.S. Department of Education. For a list of schools which meet these criteria, please refer to Department of Education Accreditation page.

Foreign Education: If you are using education completed in foreign colleges or universities to meet the qualification requirements, you must show the education credentials have been evaluated by a private organization that specializes in interpretation of foreign education programs and such education has been deemed equivalent to that gained in an accredited U.S. education program; or full credit has been given for the courses at a U.S. accredited college or university. If you are qualifying based on foreign education, you must submit proof of creditability of education as evaluated by a credentialing agency.

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