Charles Todd
Senior Attorney at IRS Office of Chief Counsel (L&A) | LL.M. Taxation | J.D. | J.M. | Veteran
- Role
- Senior Attorney at Internal Revenue Service
- Location
- Jacksonville, FL, US
- LinkedIn followers
- 500 followers
About Charles Todd
I am a Senior Attorney with the IRS Office of Chief Counsel, advising on complex…
Experience
Senior Attorney
Sep 2022 — Present · Jacksonville, FL, US
Core Roles• Senior legal advisor and attorney of record for complex federal tax litigation and advisory matters• Member of the IRS Digital Assets Cadre, advising on cryptocurrency enforcement, blockchain reporting, and digital asset controversies• Coordinator of cross-agency legal strategy, including DOJ, USAO, Appeals, Collection, Exam, and InsolvencyTax Court Litigation• Passive Activity Loss (PAL)• Syndicated Conservation Easements (SCE)• Estate & Gift (E&G) taxation• Virtual Currency & Cryptocurrency• Charitable Contributions• Gambling Losses• Micro-captive insurance structures• Civil and fraud penalties (IRC §§ 6651)• Taxpayer Identity Theft• Innocent Spouse Relief• Collection Due Process (CDP), lien and levy defense• Settlement negotiation and resolution• Interest abatement challenges and other statutory and procedural matters (e.g, 1099-B, 1099-R, 1099-INT, 1099-SA…)Advisory & Strategic Counsel• Draft legal memoranda and coordinate with National Office on high-stakes settlements and procedural determinations• Lien and levy authority reviews; nominee and alter ego analyses• Successor-in-interest and jeopardy assessments• Closing agreements and offers in compromise for businesses with $100M+ in gross receipts• FOIA response oversight, metadata redaction, and IRC §6103 compliance• Refund claim defense and erroneous refund recovery (ERC, Tax debt judgment reductions and foreclosure recommendations• Bankruptcy litigation support and passport certification determinations for seriously delinquent taxpayersAgency & Litigation Support• Legal referrals and coordination with DOJ and U.S. Attorney’s Offices (USAO)• Support for the Independent Office of Appeals• Litigation hold issuance and legal record preservation• Review and approval of statutory notices of deficiency (SNODs)• Summons enforcement and investigatory legal support
Education
Coastal Carolina University
Bachelor of Arts - B.A., Multi/Interdisciplinary Studies, Law and Society
2011 — 2013
Horry-Georgetown Technical College
Associate of Arts and Sciences - A.A.S., Legal Assistant/Paralegal cert.
2009 — 2011
United States Navy
Electrical and Electronics Engineering
2013 — 2017
Appalachian School Of Law
Master's degree J.M., Law
2018 — 2020
University of Denver - Sturm College of Law
Master of Laws - LL.M., Tax Law/Taxation
Appalachian School Of Law
Doctor of Law - J.D., Law
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