Practice Areas: Tax, Business Litigation, White Collar Crimes
Licensed in Washington since: 1975
Education: University of California College of the Law, San Francisco
Selected to Super Lawyers: 2003 - 2024 Robert Chicoine Law
66 S. Hanford StreetSuite 300
Seattle, WA 98134-1826 Phone: 206-467-9000 Email: Robert Chicoine Visit website
Details
Robert Chicoine advises clients in matters of state and federal taxation, be it planning to minimize tax disputes, effectively resolving administrative scrutiny by taxing authorities, or defending clients in litigation when tax controversies cannot be settled. He has been called upon to assist accountants and lawyers as an expert on issues of federal taxation and has been engaged by tax agencies in U.S. territories as a lead lawyer in complex litigation. His clients typically include corporations, partnerships, estates, and individuals.
Mr. Chicoine is a seasoned lawyer who has tried cases throughout the United States in the U.S. Tax Court and U.S. district courts. He has appeared before several appellate courts, including the U.S. Supreme Court. Over his distinguished legal career, Mr. Chicoine has represented clients in administrative, civil and criminal tax proceedings involving diverse issues in all phases of tax controversy. He has handled hundreds of cases before the Internal Revenue Service, Department of Justice, and revenue departments of state governments. Many of his most successful results are those that have never been published because they were resolved by negotiation. His priority is to cost effectively settle tax disputes without litigation, but if that is not possible, he will passionately defend his clients in court.
Mr. Chicoine offers his clients the benefit of having worked for the Chief Counsel’s Office of the Internal Revenue Service (IRS), where he gained valuable experience as a Senior Trial and Tax Attorney for the IRS, and then as the founder of a law firm with a national reputation. He knows how the process works from the perspective of both sides. He also offers his clients the practical experience of having “worked in the trenches” as a court room lawyer who is responsible for the outcome of his client’s case.
Prior to Robert Chicoine Law, Mr. Chicoine was a founder of Chicoine and Hallett where he practiced for over 40 years and was instrumental in its achievement as a tax specialty firm of national repute.
As an offshoot of his tax practice, it is not unusual for Mr. Chicoine to be asked by clients to assist them with his negotiating skills in business transactions such as the valuation and sale of operating corporations and the resolution of commercial disputes.
Mr. Chicoine is admitted to practice in the States of Washington, California, and Arizona.
Employment History
Senior Trial and Tax Attorney, Office Chief Counsel, Department of Treasury (1971-1977)
Founder and Partner: Lucas, Glase and Chicoine (1977-1982)
Founder and Shareholder, Chicoine & Hallett PS (1983-2013)
Founder and Partner, Chicoine Law Group LLC (2013-present)
Admissions and Affiliations
California State Bar
Washington State Bar
Arizona State Bar
United States Supreme Court
United States Tax Court
United States Court of Federal Claims
United States Courts of Appeal for the Ninth and Tenth Circuits
U.S. District Court, Western District of Washington
U.S. District Court, Eastern District of Washington
U.S. District Court, Guam
U.S. District Court, Colorado
U.S. District Court, Southern District of California
U.S. District Court of Alaska
U.S. District Court of Arizona
First Admitted: 1971, California
Professional Webpage: http://www.chicoinelaw.com/attorney/robert-chicoine.php
- Robert Chicoine Law just recently defended the first Electronic Sales Suppression prosecution in the United States and negotiated and drafted the first statutory imposed monitoring agreement in the United States, a prototype for monitoring agreement in 25 other states with similar statutes. Robert Chicoine is currently defending the largest retail sales tax and Electronic Sales Suppression prosecution in the history of Washington state. Robert Chicoine Law completed an eight day trial before the United States Tax Court involving the clients’ alleged Transferee Liability resulting from the sale of their stock in a family business to a purchaser who subsequently failed to pay federal and Oregon State corporate income taxes. Mr. Chicoine was the lead counsel against the IRS. The IRS alleges the clients participated in an Intermediary Transaction and seeks $23,000,000 in taxes dating back to 2003, plus interest. The government was represented by four trial attorneys and relied upon an expert witness whom it agreed to pay almost $250,000 for his opinion and testimony. Mr. Chicoine was co-lead counsel in an eight day trial in the U.S. federal district court in Denver, Colorado which sought a $29,000,000 tax refund arising out of an alleged Son of Boss transaction. The case was one of the few such cases to result in a judgment for the taxpayer. There too, the Department of Justice called a financial expert witness to testify against the taxpayer. The IRS had paid the witness approximately $1,000,000 per year to testify in similar cases. The testimony of the IRS expert, who was crossed examined by Mr. Chicoine at trial, was rejected by the court. Mr. Chicoine appeared as co-counsel before the U.S. Supreme Court in a case which had been previously lost in the U.S. Tax Court and the Tenth Circuit Court of Appeals on an issue involving statutory interpretation in the context of basis calculation for shareholders for a closely held Sub Chapter S business. The U. S. Supreme Court ruled in favor of our clients in a rare eight to one opinion overturning the lower courts’ rulings. Mr. Chicoine was engaged by a bankruptcy trustee in Idaho to pursue a contact claim of approximately $10,000,000 on the debtor’s behalf against the large Oklahoma chemical company, Kerr-McGee, for breach of contract. Mr. Chicoine successfully defended Kerr-McGee’s motion for summary judgment, and then won his cross motion for partial summary judgment against Kerr-McGee. The case was subsequently settled as a result. Mr. Chicoine was engaged by the beneficiaries of their father’s estate to defend an IRS estate tax audit which focused upon the valuation of the decedent’s interest in his highly successful family business. The decedent had transferred much of his interest to family members in related transactions, the substance of which was challenged by the IRS. The IRS attempted to disregard the transactions and challenged the valuation used on the estate tax return by relying, in part, on a subsequent sale of the business at a price significantly greater than the reported value. Mr. Chicoine was able to avoid litigation and negotiated a resolution and valuation that was extremely beneficial to the beneficiaries.
- Adjunct Professor, Federal Tax Procedures, University of Washington School of Law, Graduate Program in Taxation (LLM), (1995-2003) Adjunct Professor, Federal Tax Research, Golden Gate University School of Law, School of Taxation, (1977-1980).In addition to teaching as an adjunct professor at two university law schools, Mr. Chicoine has spoken before various professional organizations and published articles on a wide variety of topics including:The Ins and Outs of Tax Litigation Representing Potential Defendants In Federal Tax Investigations How to Deal With the IRS Transparency and International Information Exchange—Are There Any Tax Havens Left?; Information Exchange Pursuant to Tax Treaties Accuracy Related Penalties—the Slippery Slope to Strict Liability When a Loophole Becomes a Noose—Perils of Tax Advice Judicial Deference to IRS Rulings and Regulations Ethical Problems Inherent in Estate Tax Controversies The Scope of Privilege for Accountants--When They Should Get a Lawyer Involved Tax Considerations When Funding a Criminal Defense Aggressive IRS Collection Efforts-What if Anything You Can Do The Use of Administrative Summonses by the IRS Selected Topics Regarding Tax Practice and Procedures The Impact of Ames v. Commissioner Civil Penalties - Their Restructuring and Effect Tax Controversies-Penalties and the Taxpayer Bill of Rights Egg Shell Audits How Offers in Compromise Work; Tax Shelters.
- Mr. Chicoine has been recognized by his peers as one of the Best Lawyers in America in three areas: Tax, Civil Tax Litigation, and White Collar Criminal Defense (Tax) and has been repeatedly recognized as a Washington State Super Lawyer, and one of Washington State’s Top Lawyers. He is also listed in the Bar Register of Preeminent Lawyers, Who's Who of Outstanding Professionals, and Who's Who in Criminal Defense Law. He has been given a 10/10 Superb Rating by AVVO and a Preeminent Peer Review AV rating by Martindale-Hubble National Law Directory for legal ability and ethics. He was recently selected for inclusion in the National Trial Lawyers: Top 100 Trial Lawyers for 2014. The Chicoine Law Group has been recognized as one of the Best Law Firms in America by U.S. News and World Report for White Collar Criminal Defense, Taxation and Civil Tax Litigation.
Office location for Robert Chicoine
66 S. Hanford Street
Suite 300
Seattle, WA 98134-1826
Selections
- Super Lawyers: 2003 - 2024