Zachary Montgomery

Zachary J. Montgomery is a dual-credentialed attorney and CPA. He practices in the area of federal and state tax litigation, white-collar defense, business and tax planning, and litigation. Mr. Montgomery has experience representing both businesses and individuals in federal tax controversies, including appeals, examinations, penalty abatement and collection matters. He has also represented taxpayers—from small organizations to Fortune 500 companies—with Texas franchise tax refund claims, audits, penalty abatement, and corporate structuring.

Mr. Montgomery is a graduate of the University of Virginia School of Law where he focused his studies on corporate and tax law and served on the editorial board of the Virginia Tax Review. Prior to joining the firm, he gained experience with PricewaterhouseCoopers, LLP, and a regional firm, focusing on federal and state tax controversies. His previous experience also includes Ernst & Young, Deloitte & Touche, and a judicial student clerkship with the First Court of Appeals of Texas.

Mr. Montgomery is a graduate of Texas A&M University, where he graduated Summa Cum Laude and received his B.B.A. with a double major in Accounting and Business Honors and his M.S. in Management Information Systems. While attending Texas A&M, he developed his business acumen, working as an enterprise risk consultant and financial analyst.

Mr. Montgomery is a member of the Dallas Bar Association, Association of Certified Fraud Examiners (ACFE), and Texas Society of CPAs (TXCPA), and serves on the TXCPA Federal Tax Policy Committee. Mr. Montgomery is also an avid writer and author and was named JD Supra Reader’s Choice Top Author in 2021.

Representative Matters

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  • University of Virginia School of Law, J.D.
    • Editorial Board, Virginia Tax Review
  • Texas A&M University, summa cum laude, M.S. in Management Information Systems
  • Texas A&M University, summa cum laude, B.B.A. in Accounting and Business Honors

Bar and Court Admissions

  • Texas
  • United States District Court for the Eastern District of Texas
  • United States Tax Court

Honors & Awards

  • JD Supra Readers’ Choice Top Author, 2021

Professional Associations and Memberships

  • State Bar of Texas
    • Tax Section
  • Dallas Bar Association
  • Collin County Bar Association
  • American Association of Attorneys-CPAs
  • Association of Certified Fraud Examiners (ACFE)
  • Texas Society of CPAs (TXCPA)
    • Federal Tax Policy Committee
  • American Institute of Certified Public Accountants


  • Author, “Missed Window—Taxpayer Loses Chance to Sue IRS on Claim for Refund”, JD Supra, August 19, 2021
  • Author, “Back Off, IRS!—Accounts Holding Advance Child Tax Credit Payments Immune from Levy?”, JD Supra, August 13, 2021
  • Author, “Tough Luck, Taxpayer!—IRS Continues to Levy on Social Security Benefits”, JD Supra, August 4, 2021
  • Author, “‘Extreme Personal Hardship’ Doesn’t Excuse Trust Fund Recovery Penalties”, JD Supra, July 23, 2021
  • Author, “Ill and Illiterate—Torres v. Commissioner”, JD Supra, June 16, 2021
  • Author, “Passport Revocation Challenges—Shitrit v. Commissioner”, JD Supra, June 8, 2021
  • Author, “Tax Court Addresses Reasonable Cause Standard and Tax Penalties”, JD Supra, May 18, 2021
  • Author, “But, Your Honor, There’s A Coronavirus Pandemic, Part II—United States v. Ishmael”, JD Supra, March 5, 2021
  • Author, “Forget Uncle Sam—Watch Out for the Tax Comptroller”, JD Supra, February 9, 2021
  • Author, “COVID-19 Relief? Think Again!—Corporate Charitable Contributions for Disaster Relief”, JD Supra, February 5, 2021
  • Author, “Mere Change?—'F’ Reorganization Qualifies in Spite of Change in Plan”, JD Supra, January 29, 2021
  • Author, “Skating on Thin Ice: IRS Does Not Recognize Organization’s 501(c)(3) Status”, JD Supra, January 13, 2021
  • Author, “Death Doesn’t Stop the IRS—Failure to File FBARs”, JD Supra, December 17, 2020
  • Author, “It’s Note Too Late!—Untimely S Elections”, JD Supra, December 8, 2020
  • Author, “Bare Bitcoins—No Fourth Amendment Privacy in Virtual Currency Records”, JD Supra, October 27, 2020
  • Author, “Boo!—Personal Liability Exposure for Your Business’ State Taxes”, JD Supra, October 15, 2020


  • “Married to My (Ex)Spouse’s Taxes: Innocent Spouse Relief,” CPA Academy Webinar, March 3, 2021
  • “Married to My (Ex)Spouse’s Taxes: Innocent Spouse Relief,” CPA Academy Webinar, February 1, 2021
  • “Married to My (Ex)Spouse’s Taxes: Innocent Spouse Relief,” CPA Academy Webinar, February 8, 2021