About

Guinevere Marie Moore is a tax litigator who represents taxpayers in civil and criminal tax controversies.  She advocates for taxpayers at the IRS examination and appeals levels and, if a settlement with the IRS cannot be reached, in litigation. 

Ms. Moore has represented hundreds of taxpayers throughout her career, and draws on her experience in working with her clients, with the IRS, and with opposing counsel to help craft and execute the best possible plan to resolve the issues her clients are facing.  Ms. Moore has successfully defended taxpayers against assessment of all types of federal tax, including income tax, employment tax, estate tax, gift tax, civil penalties, and criminal penalties. 

Ms. Moore’s significant experience in practicing before the IRS and in the United States Tax Court enables her to work together with her clients to determine the best path forward to resolving the tax dispute – whatever Internal Revenue Code section may be at issue.  The Internal Revenue Code contains thousands of provisions, and no tax professional has encountered them all.  But having years of experience with the procedural hurdles that a taxpayer has to jump through in order to resolve a disagreement with the IRS over how much tax is due facilitates a much easier journey towards agreement or resolution through litigation.

Ms. Moore particularly enjoys the client counseling that she performs in her role as a taxpayer’s advocate. Having navigated hundreds of disputes with the IRS she is able to guide clients through what is often the most difficult crisis they are facing in their lives.  Her clients will never wonder what comes next, or how the most recent development will impact them, because Ms. Moore routinely explains the process, the anticipated timeline, our strategy, and how all of the pieces come together. 

Ms. Moore is actively involved in the American Bar Association, Section of Taxation.  She is the co-vice chair of the Standards of Practice Committee of the Section of Taxation.  In that role, she helps design and implement programming designed to ensure certain ethical standards are met in tax representation nationwide.  She is a frequent speaker at national and local conferences on topics related to tax, ethics, and the ethics of tax. 

Ms. Moore launched what has become an active pro bono program designed to help low income taxpayers receive representation that they could otherwise not afford.  As part of this process, she co-authored and designed a four-part training series for representing low-income taxpayers before the IRS.  She has been recognized for her pro bono work as the volunteer of the year by the Center for Economic Progress, and has represented over one hundred clients pro bono.

Ms. Moore lives in Chicago with her husband and her four children.

Experience

Ms. Moore’s recent IRS Administrative and IRS Appeals experience includes:

  • Convincing the IRS to abate over $1 million in IRC § 6721 intentional disregard penalties assessed against a corporate taxpayer at the IRS administrative and appeals levels.
  • Representing a corporate taxpayer in an employment tax examination that ended in no changes and no additional tax assessed.
  • Successfully abating over $1 million in penalties for a taxpayer at the administrative level.
  • Representing hundreds of taxpayers who are either voluntarily disclosing foreign financial accounts and assets or are unable to do so due to pending examinations.

Ms. Moore’s recent tax litigation experience includes:

  • Successfully litigating whether a taxpayer was liable as a transferee as a result of an alleged Midco transaction in Alterman v. Commissioner, T.C. Memo 2015-231.
  • Successfully litigating whether a taxpayer materially participated in a real estate business in Lamas v. Commissioner, T.C. Memo 2015-59.

Ms. Moore’s overall experience includes:

  • Successfully pursuing innocent spouse claims for multiple taxpayers.
  • Successfully pursuing claims for refund at various levels.
  • Representing multiple taxpayers in Midco transferee liability cases, both reaching amicable settlement with the IRS and awaiting final decision at various court levels.
  • Representing taxpayers in various matters before the IRS examinations and appeals divisions in disputes regarding income tax, estate and gift tax, executive compensation, excise tax, and TEFRA partnership disputes. 

Honors & Awards

  • Rising Star, Illinois Super Lawyers magazine, 2017
  • Rising Star, Illinois Super Lawyers magazine, 2014-2016
  • 2014 Volunteer Champion Award, Center for Economic Progress (CEP)
  • Nolan Fellowship, American Bar Association Section of Taxation, 2014
  • Public Interest Law Initiative Fellow, Domestic Violence Legal Clinic, Chicago, 2008

Professional Activities

  • Co-Vice Chair of American Bar Association, Section of Taxation, Standards of Practice Committee
  • Chicago Bar Association, Taxation Committee

Speaking Engagements

  • Reasonable Reliance Defense and Work Product Protection, Federal Bar Association 42nd Annual Tax Law Conference, March 9, 2018
  • Ethical Issues/Experts in Federal Tax Practice, Federal Bar Association 42nd Annual Tax Law Conference, March 9, 2018
  • 280E - Current Law and Analysis, ABA Tax Section 2018 Midyear Meeting, San Diego, CA, February 8-10, 2018
  • Preparing Witnesses to Testify, ABA Tax Section 2018 Midyear Meeting, San Diego, CA, February 8-10, 2018
  • Marijuana: Ethical and Legal Issues in Representing Taxpayers, ABA 34th Annual National Institute on Criminal Tax Fraud and Seventh Annual National Institute on Tax Controversy, December 6, 2017
  • Ethical Issues in Preserving and Collecting Evidence, ABA Tax Section 2017 May Meeting, May 12, 2017
  • Responding to IRS Penalties, IRS Nationwide Tax Forum, Chicago, IL, July 13 and 14, 2016
  • Nuts and Bolts of Tax Court Litigation: Trial, ABA Mid-Year Meeting, January 2016
  • Disclosure, FOIA and Tax Litigation, ABA Mid-Year Meeting, January 2016
  • Unreported Offshore Assets – Disclosures and Audits 3rd Annual International Tax Enforcement Conference, October 16, 2015
  • American Bar Association's 2015 Joint Fall CLE Meeting Ethical Issues Arising in Discovery; Kicking the Habit: Using Kovel Responsibly; Aggressive IRS Audit Techniques – Tales from the Trenches (Moderator), September 17-19, 2015 Initiating a New Client Engagement – Ethical and Practice Standards American Bar Association, Section of Taxation, May Meeting, Washington, D.C., May 8, 2015
  • American Bar Association Section of Real Property, Trust and Estate Law 2015 Spring Symposia CLE Meeting Moderator, Get Ready: Global Tax Enforcement is on the Rise for High-Wealth Taxpayers, April 30-May 1, 2015 Career in Tax Law Panel Northwestern University School of Law, March 18, 2015
  • American Bar Association Section of Taxation 2015 Midyear Meeting Ethical Issues in Federal Tax Practice - The Government Perspective, January 29-31, 2015
  • The Illinois CPA Society 2014 Tax Conference Offshore Tax Compliance: Often Forgotten Informational Forms and the IRS's Offshore Voluntary Disclosure Programs, November 12, 2014
  • American Association of Attorney-Certified Public Accountants (AAA-CPA) Fall Meeting and Education Conference Offshore Tax Compliance: Often Forgotten Informational Forms and the IRS's Offshore Voluntary Disclosure Programs, November 5-8, 2014
  • American Bar Association Section of Taxation 2013 May Meeting Moderator, Ethical Issues in Federal Tax Practice - The Government Perspective, May 10, 2013 Proposed Circular 230 Regulations: Adopting a Principles-Based Approach to Written Tax Advice Annual Philadelphia Tax Conference, November 14, 2012
  • American Bar Association Joint Fall CLE Meeting Panelist, Addressing Concerns About the Ethical Judgments for a Supervising Attorney; Moderator, Ethical Issues in Federal Tax Practice - The Government Perspective, September 13-15, 2012

Education

  • DePaul University, B.A., with highest honors
  • DePaul University College of Law, J.D., cum laude

Court Admissions

  • Illinois Supreme Court
  • United States District Court for the Northern District of Illinois, Trial Bar
  • United States District Court for the Central District of Illinois
  • United States District Court for the Eastern District of Wisconsin
  • United States Court of Appeals for the First Circuit
  • United States Court of Appeals for the Third Circuit
  • United States Court of Appeals for the Sixth Circuit
  • United States Court of Appeals for the Seventh Circuit
  • United States Court of Appeals for the Eighth Circuit
  • United States Court of Appeals for the Ninth Circuit
  • United States Court of Appeals for the Tenth Circuit
  • United States Court of Appeals for the Eleventh Circuit
  • United States Court of Appeals for the Federal Circuit
  • Supreme Court of the United States
  • United States Tax Court