Curt Smith has an extensive background in tax controversy and litigation. After finishing law school, Mr. Smith went to work as a trial attorney with the United States Department of Justice, Tax Division, through the Attorney General’s Honors Program. For the government, Mr. Smith litigated a number of civil tax cases, with issues ranging from damages lawsuits against the government, IRS collection, trust fund recovery penalties, IRS summons (including John Doe Summons) enforcement, excise tax (including oil and gas, and transportation tax issues), constructive dividends, employment tax (including Railroad Retirement Tax Act issues) and substance over form/economic substance refund suits.
After transitioning out of government service, Mr. Smith worked for a public accounting firm, in their tax advocacy and controversy services team. Mr. Smith advocated on behalf of clients through Private Letter Ruling (PLR) requests, IRS Appeals conferences, penalty abatement requests, collection due process hearings, and IRS audits.
