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.
Abatement of failure-to-file, failure-to-pay, and failure-to-make estimated tax penalties totaling more than $200,000.
Represented clients in obtaining full abatement or waiver of trust fund recovery penalties.
Represented clients in obtaining full abatement or waiver of federal tax penalties, including failure-to-file and failure-to-pay penalties and international reporting obligation penalties such as Forms 5471, 5472, 3520, 3520-A, 8938, and FBAR.
Represented innocent spouses in obtaining full innocent spouse relief under I.R.C. § 6015.
Counsel for clients in Collection Due Process (CDP) hearing matters, including representation before the IRS Independent Office of Appeals and United States Tax Court.
Represented client in criminal tax investigation by IRS Criminal Investigation Division involving allegations of income tax evasion; “killed investigation,” obtaining agreement from IRS CID not to seek prosecution against client.
Criminal defense counsel for client indicted for tax evasion and failure to pay employment taxes. Obtained resolution for client that included a restitution amount of pennies on the dollar.
Represented clients with respect to successful submissions under the IRS Streamlined Filing Compliance Procedures.
Represented clients with respect to unfiled tax return matters including preparation and submission of Offshore Voluntary Disclosure Program (OVDP) materials, Streamlined Filing Compliance Procedure materials, and other IRS voluntary disclosure programs.
Counseled clients on IRS collection alternatives such as offers in compromise, resulting in significant reductions in and/or eliminations of tax debts.
Authored tax opinions and provided advice on matters including those relating to the taxability of settlement awards and the deductibility of attorney fees.
Provided legal counsel to clients on tax effects and structuring of domestic and international business transactions, including formations, acquisitions, dispositions, mergers, and reorganizations.
Represented companies in sales tax audits. Obtained “no-change” audit result for client.