Guinevere M. Moore

Top rated Tax attorney in Chicago, Illinois

Moore Tax Law Group LLC
Guinevere M. Moore
Moore Tax Law Group LLC

Practice Areas: Tax, White Collar Crimes; view more

Licensed in Illinois since: 2008

Education: DePaul University College of Law

Selected to Super Lawyers: 2023 - 2024 Selected to Rising Stars: 2014 - 2018

Moore Tax Law Group LLC

2205 W Armitage Avenue
Suite 1
Chicago, IL 60647 Visit website

Details

Guinevere Moore represents taxpayers in significant disputes with the Internal Revenue Service, the Department of Justice, Tax Division, and state taxing agencies.  She is the Managing Member of Moore Tax Law Group, LLC, a tax controversy and tax litigation firm with offices in Chicago and New York.  

Guinevere has over fifteen years of experience helping taxpayers resolve significant disputes with the IRS and state tax agencies.  She routinely represents taxpayers in high-stakes criminal and civil tax disputes.  At Moore Tax Law Group LLC, we take a holistic approach to representing clients.  It isn’t possible to accomplish the best possible outcomes for our clients unless we’ve gotten to know our clients and understand what the best possible outcome could be to the client.  Some clients want to win at all costs.  Some clients want to resolve the issue as quickly as possible, and are willing to concede issues they would likely win in litigation in order to put the problem with the IRS behind them.  Most fall somewhere in between.  Guinevere gets to know her clients and ensures that she has a deep understanding of their needs and preferences before developing a strategy for the case.  

She is a frequent speaker and author, routinely publishing articles and speaking at conferences around the world on tax controversy and tax litigation in Forbes, Bloomberg, and Tax Notes.  

Guinevere lives in Chicago with her husband and their four children.  She enjoys being active and all of her best ideas come to her while riding her bike to work, running or walking, or rowing.  

Civil Tax Defense 

Guinevere represents taxpayers in significant civil tax disputes of all kinds – assessable penalties, income, estate, gift, payroll, excise, and sales tax.  She has resolved disputes on behalf of individuals, partnerships, corporations, trusts, and estates.  

Every taxpayer wants to resolve cases with the IRS without litigation, and it is always our goal to work with the IRS to try to reach an agreement administratively.  Guinevere has assisted taxpayers in resolving disputes with the IRS at the examination level and at IRS appeals, and these agreements reached without litigation are often the most rewarding.  

If an agreement with the IRS can’t be reached, Guinevere has significant experience litigating on behalf of her clients.  She has acted as lead counsel for taxpayers in United States Tax Court, Federal District Court, and the Court of Federal Claims, as well as in Courts of Appeal around the country, including the Seventh Circuit, the Eleventh Circuit, and the D.C. Circuit.  She has litigated on behalf of taxpayers in the Supreme Court of the United States representing amicus curie, twice leading to taxpayer favorable outcomes.  

In recent years Ms. Moore has increased her representation of clients in valuation matters, including representing appraisers and taxpayers defending valuations.  She is defending clients against imposition of various penalties associated with technical foot-faults associated with appraisals and the technical guidelines set forth in Treasury Regulations 26 CFR section 1.170A-14 and associated regulations.  

Criminal Tax Defense and White Collar Defense 

Guinevere and the Moore Tax Law Group team represent clients in federal criminal tax investigations and white collar cases all over the country and cooperate with local counsel.  Most of Guinevere’s criminal tax and white collar defense work is on cases no one has ever heard of and never will.  That is because no one wants to win a criminal tax case, they want the case to be resolved without formal charges ever being brought.  Guinevere works to resolve her cases quietly, cooperatively, by demonstrating why the government should not bring charges.

If it is not possible to avoid charges entirely, Guinevere will work to accomplish her client’s individual objectives to resolve the case.  This can mean working with the government to craft a creative plea and sentencing agreement, or it might mean going to trial.  The decision of whether to accept a plea or proceed to trial is a deeply personal one for each criminal defendant, and Guinevere works with her clients to ensure that they have all of the information necessary to make the best decision possible.

If a client decides to go to trial, Guinevere and her team are ready and experienced.  The Pew Research Center recently reported that fewer than 1% of federal criminal defendants were acquitted in 2022.  Moore Tax Law Group secured a complete acquittal in the summer of 2023 after a twelve-week jury trial of their client in the Northern District of Georgia with Guinevere Moore as lead counsel.  

Professional Involvement

Guinevere is an active member of the tax bar.  She is an active member of the American Bar Association, Section of Taxation.  She is currently serving on Council and has previously served as the chair of the Standards of Tax Practice Committee.  In that role, she helps design and implement continuing education seminars for attorneys and tax professionals focusing on civil and criminal tax disputes and tax ethics.  

Community Involvement

After her twin boys were born two months early and spent two months in the NICU, Guinevere was introduced to the March of Dimes.  They are alive today due in large part to the life-saving treatment that the March of Dimes developed.  Guinevere and her husband have since become members of the Chicago Board of Directors of that organization and are actively involved in helping improve the health of all moms and babies.

Her favorite charities to support include the Irving Park Food Pantry, The Chicago Park District, Friends of Disney II, and Hamlin Park Baseball Association.  

Pro Bono 

Guinevere and Moore Tax Law Group have a strong commitment to pro bono.  

We are firmly committed to systemic taxpayer advocacy on a pro bono basis.  We have represented non-profit organizations before the Supreme Court of the United States to further systemic fairness in administration of the tax system.  

-         Amicus Curie counsel for The Center for Taxpayer Rights (CTR) in Bittner v. United States, 21-1195 (February 28, 2023), decision in favor of the taxpayer;

-         Amicus Curie counsel for CTR in Bedrosian v. United States, 22-598 (petition for writ of certiorari denied) 

-         Amicus Curie counsel for The American College of Tax Counsel in Marinello v. United States,  16-144 (March 21, 2018), decision in favor of the taxpayer

Representation for taxpayers who cannot afford representation helps all tax administration be more fair and just.  Most of our pro bono cases are resolved at the IRS level.  For example, we recently secured complete abatement of information reporting penalties for an Illinois School District pro bono at the IRS level.  Some of the individual taxpayer cases taken on pro bono or low bono in United States Tax Court have resulted either complete or almost complete taxpayer victories, including:

Hughes v. Commissioner, 6283-21

Taxco Sterling v. Commissioner, 32579-21L

Thompson v. Commissioner, 4165-19

Pryor v. Commissioner, 13514-17

Bartom v. Commissioner, 13236-15

Heindl v. Commissioner, 3329-11

Satchu v. Commissioner, 14431-11L

Practice areas

Tax: Business, Criminal Defense: White Collar

Focus areas

Criminal Law - Federal, Tax Law, White Collar Crime

  • 70% Tax: Business
  • 30% Criminal Defense: White Collar

First Admitted: 2008, Illinois

Professional Webpage: https://www.mooretaxlawgroup.com/attorney/moore-guinevere-m/

Honors/Awards:
  • Chambers High Net Worth Guide, USA, Tax: Private Client, 2022, Band 2
  • Volunteer of the Year, LadderUp
  • Public Interest Law Initiative Fellow, Domestic Violence Legal Clinic, Chicago
  • Nolan Fellowship, American Bar Association Section of Taxation
  • Volunteer Champion Award, Center for Economic Progress (CEP)
  • Rising Star, Illinois Super Lawyers Magazine
  • Chicago’s Notable Women Lawyers, Crain’s
  • Legal 500, Firms to Watch – U.S. Taxes: Contentious: Moore Tax Law Group LLC, 2022
  • America’s Top 100 Criminal Defense Attorneys for Illinois, 2022
  • International Tax Review — World Tax, 2022, Highly Regarded Practitioner for Tax Controversy, USA
  • Best Lawyers in America, 2022
  • Chambers High Net Worth Guide, USA, Tax: Private Client, 2022, Band 2 — The Moore Tax Law Group LLC
Pro bono/Community Service:
  • Represent taxpayers who cannot afford legal representation before IRS and United States Tax Court.
  • Prepared amicus brief for the Center for Taxpayer Rights in a petition for writ of certiorari to the United States Supreme Court., 2022
Bar/Professional Activity:
  • Member of the Board of Directors, Accounting and Financial Women's Alliance
  • Chicago Bar Association, Taxation Committee
  • American Bar Association, Section of Taxation, Chair of the Janet Spragens Pro Bono Award Committee
  • Chicago Bar Association
  • American Bar Association
  • Supreme Court of the United States
  • U.S. Tax Court
  • U.S. Court of Federal Claims
  • U.S. Court of Appeals Federal Circuit
  • U.S. Court of Appeals 11th Circuit
  • U.S. Court of Appeals 10th Circuit
  • U.S. Court of Appeals 9th Circuit
  • U.S. Court of Appeals 8th Circuit
  • U.S. Court of Appeals 7th Circuit
  • U.S. Court of Appeals 6th Circuit
  • U.S. Court of Appeals 3rd Circuit
  • U.S. Court of Appeals 1st Circuit
  • U.S. District Court Western District of Wisconsin
  • U.S. District Court Eastern District of Wisconsin
  • U.S. District Court Central District of Illinois
  • U.S. District Court Northern District of Illinois, Member of the Trial Bar
  • Supreme Court of Illinois
  • Immediate past Chair of the Standards of Practice Committee, American Bar Association Section of Taxation, 2022
  • Conference Chair, Women Who Count, 2020
Educational Background:
  • DePaul University, B.A. With Highest Honors, 2003
Scholarly Lectures/Writings:
  • I am a regular contributor to Forbes IRS Watch , Contributor, IRS Tax Watch, Forbes, 2020
  • Guinevere Moore presented Nuts & Bolts of Tax Court Litigation: Trial and Stipulations of Fact, Witness Preparation and Impeachment, and the Rules of Evidence the American Bar Association Tax Section 2016 Midyear Meeting in Los Angeles, CA on January 30, 2016
  • Guinevere Moore presented Responding to IRS Penalties at the IRS Nationwide Tax Forum in Chicago, IL on July 13 and 14, 2016.
  • Guinevere Moore presented Ethical Issues in Representing Tax Professionals at the American Bar Association Section of Tax 2017 May Meeting on May 12, 2017.
  • Guinevere Moore presented National Institutes on Criminal Tax Fraud and Tax Controversy for the American Bar Association in Las Vegas, NV on December 6 – 8, 2017.
  • Guinevere Moore presented Preparing Witnesses to Testify and Current Law and Analysis at the American Bar Association 2018 Midyear Meeting in San Diego, CA, February 8 – 10, 2018.
  • Guinevere Moore presented D.C. Ethical Issues/Experts in Federal Tax Practice and Reasonable Reliance Defense and Work Product Protection at the Federal Bar Association 42nd Annual Tax Law Conference on March 9, 2018.
  • Guinevere Moore presented Statutes of Limitations on IRS Examinations and Ethical Issues Regarding Partnership Representatives at the American Bar Association Section of Taxation’s 2018 Fall Tax Meeting on October 5, 2018
  • Guinevere Moore presented Civil Tax Workshop: Responding to Summonses and What Everyone Needs to Know About Cryptocurrency: Part One: Tax Treatment of Cryptocurrency Transactions; Part Two: Enforcement When Cryptocurrency Transactions Go Wrong at the America Bar Association’s 35 Annual National Institute on Criminal Tax Fraud and 8th Annual National Institute on Tax Controversy in Las Vegas, NV on December 13 and 15, 2018.
  • Guinevere Moore presented Partnership Representatives: New IRS Final Regulations Under Section 6223 and Challenges for Pass-Through Entities in a Strafford webinar on January 30, 2019.
  • Guinevere Moore presented Updated Voluntary Disclosure Practices: Is this the Correct Path for your Noncompliant Client? At the Federal Bar Association Tax Law Conference in Washington, D.C. on March 8, 2019
  • Guinevere Moore presented Representing Taxpayers During Summons and Other IRS Interviews – Potted Plant v. Rambo at the ABA Section of Taxation in Washington, D.C. on May 10, 2019
  • Guinevere Moore presented Rock-Partnership Representative-Hardplace at the NYU Annual Tax Controversy Forum in New York, NY on June 20, 2019.
  • Guinevere Moore presented Rock-Partnership Representative-Hardplace at the NYU Annual Tax Controversy Forum in New York, NY on June 20, 2019.
  • Guinevere Moore presented Amending LLC and Partnership Agreements to Address Tax Reform and the Current IRS Audit Rules; Tax Law Considerations, Former Partner Contributions to Tax Liability, Push-Out Elections and More at the Strafford Webinar on June 25, 2019.
  • Guinevere Moore presented Real Estate 199A Aggregation and 469 Grouping Rules: Real Estate Professionals and Safe Harbor Election at the Strafford Webinar on July 2, 2019
  • Guinevere Moore presented The Obligation to Report Tax Related Misconduct at the New England IRS Representation Conference in a webcast on November 2, 2019
  • Guinevere Moore presented Seeing through the Haze, Navigating Legalized Cannabis in Illinois at the Chicago Bar Association in Chicago, IL on November 13, 2019.
  • Guinevere Moore presented It’s a Whole New World: Defending and Litigating Partnership Adjustments Under the Bi-Partisan Budget Act of 2015 at the American Bar Associations National Institute on Criminal Tax Fraud and Tax Controversy in Las Vegas, NV on December 12, 2019.
  • Guinevere Moore presented Ethical Issues Related to Limited Scope Engagements at the American Bar Association’s Section of Taxation Meeting in Boca Raton, FL on January 30 – February 1, 2020.
  • Guinevere Moore presented When is it time for an Engagement Checkup? at the Illinois CPA Society Summit, on August 25-26, 2020.
  • Guinevere Moore is Co-Chair of Women Who Count and presenting on ‘When is it time for an Engagement Checkup?’, held from October 28-30, 2020
  • Guinevere Moore presented on Tax Controversies at NYU’s 79th Institute on Federal Taxation, Monday, November 16, 2020
  • Guinevere Moore is speaking and presenting on ‘Best Practices for an IRS Exam’ at the National Association of Tax Professionals (NATP) TAXCON, which is taking place August 24–26, 2021
  • Guinevere Moore is speaking and presenting on ‘Best Practices for an IRS Exam’ at the Illinois CPA Society (ICPAS) SUMMIT21, on August 24, 2021
  • Guinevere Moore presented at The Freeman Law International Tax Symposium, November 18th & 19th, 2021
  • Guinevere Moore was a Moderator for “IRS Enforcement Trends” 2021 IRS Representation Conference (November 19, 2021).
  • Guinevere Moore and Zhanna Ziering presented on “The Attorney-Client Privilege and Work Product Protection in Tax Court – Developments and Best Practices (Ethics)”, 2021 American Bar Association 38th National Institute on Criminal Tax Fraud and 11th Annual National Institute on Tax Controversy, December 08 -10, 2021, Las Vegas.
  • Guinevere Moore was a Panelist for “Ethics and the Federal Tax Practice” FBA Tax Law Conference (March 3, 2022).
  • Guinevere Moore and Zhanna Ziering presented on “Foreign Financial Asset Reporting-Learn From Tax Attorneys” on a webinar hosted by CDH CPA (May 19, 2022).
  • Reasonable-Reliance Defense and Work Product Protection by Guinevere Moore, ABA Tax Times, March 2018 In Estate of Marion Levine v. Commissioner, Docket No. 13370-13
  • The Sixth Amendment guarantees the right to conflict-free counsel in a criminal case
  • A Primer on Deducting Losses from Real Estate Activities for “the Rest of Us” by Elizabeth Yablonicky and Guinevere Moore, ABA Tax Times, February 22, 2019
  • Preparing Partnership Returns Under the BBA by Guinevere Moore and Elizabeth Yablonicky, Journal of Tax Practice and Procedure, February-March 2019
  • IRS Fumble: What to Do When a Tax Assessment’s Validity is Questionable by Guinevere Moore, ABA Tax Times, June 14, 2019
  • U.S. Citizens Living Abroad Should Consider Taking Advantage of New Relief Procedures by Guinevere Moore, Bloomberg Tax Daily Tax Report, Insight.
  • Virtual Currency Reality: The IRS Crack Down on Cryptocurrency, Journal of Tax Practice and Procedure Guinevere Moore examines the filing obligations for cryptocurrency holders, past IRS enforcement and IRS guidance, and next steps for IRS enforcement and cryptocurrency holders.
  • Information Return Penalties: How to avoid or contest them, The Tax Advisor   Guinevere Moore explores the vast Information Return Penalties the IRS has at its disposal and how taxpayers who are facing these penalties can avoid them or, if they are assessed, contest them.
  • Is It Time for an Engagement Check-up? by Guinevere Moore, Journal of Tax Practice & Procedure, December 2019-January 2020
  • Retroactive Notice 2017-10 Is Problematic by Guinevere Moore and Elizabeth Yablonicky, Tax Notes Federal, April 6, 2020
  • The Incompetent Authority: Questions and Answers co-authored by Guinevere Moore, ABA Tax Times, August 25, 2020
  • The Incompetent Authority: Questions and Answers co-authored by Guinevere Moore, ABA Tax Times, March 12, 2021
  • Guinevere Moore is a regular tax contributor to the Forbes blog. Her posts cover a range of tax-related topics
  • Crypto Unicorn TaxBit Joins Forces With PayPal, Coinbase, FTX And More To Make Paying Bitcoin And NFT Taxes A Whole Lot Easier
  • Build Back Better Act Would Give IRS Agents More Power And Remove Important Taxpayer Protections – Retroactively. Passage Would Be A Titanic Mistake
  • Mad At The IRS? Blame Congress, Not The Commissioner
  • Cryptocurrency Front And Center In Revised IRS Voluntary Disclosure Practice
  • DOJ Names Experienced Cybercrime Prosecutor As First Crypto Enforcement Director
Verdicts/Settlements (Case Results):
  • John Doe v. Trump, United States, and Jane Doe v. Trump, United States.  Argued on behalf of anonymous plaintiff and putative class that CARES Act provision excluding US persons who are married to ITIN Holders from Economic Impact Payment is unconstitutional.  Cases were rendered moot when Congress changed the law retroactively to award EIP payments to our clients as requested in the litigation., 2020
  • Katholos v. Commissioner, United States Tax Court Docket No. 19011-16.  The IRS sought over $4 million in taxes and penalties from my client.  I was engaged less than four months from when the case was set for trial.  I settled case for $32,371 within 90 days of being engaged. , 2021
  • Thompson v. Commissioner of Internal Revenue, decision completely in favor of the taxpayer, holding taxpayer is entitled to deduct expenses for graduate school., 2019
  • Lamas v. Commissioner of Internal Revenue, decision in favor of the taxpayer, holding taxpayer met material participation requirements and was able to deduct losses as active losses., 2015
  • Alterman v. Commissioner, decision in favor of the taxpayer, holding no transferee liability under I.R.C. 6901, 2015
Transactions:
  • Confidential IRS settlement, complete concession of just under 1 million in civil penalties., 2021
Representative Clients:
  • I represent a client who was assessed tax penalties in excess of $25 million, and I was able to get the IRS to abate over $20 million in administrative proceeds, 2022

These comments were made by fellow attorneys during the annual nomination process.

“I can truly say I have never worked with a more brilliant, motivated, inspiring, hardworking and intelligent attorney in my life. I am forever grateful to have co-counseled with Gwen and to now have a mentor in the law.”

Office location for Guinevere M. Moore

2205 W Armitage Avenue
Suite 1
Chicago, IL 60647

Phone: 312-549-9990

Selections

2 Years Super Lawyers
5 Years Rising Stars
  • Super Lawyers: 2023 - 2024
  • Rising Stars: 2014 - 2018

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