Fogarty Mueller Harris, PLLC | 360° Tax Law Expertise | 813.549.4490 info@FMHlegal.com

Brian Harris

Brian Harris

Brian Harris represents taxpayers in all matters before the IRS, including audits and appeals. He also represents clients in a variety of U.S. Tax Court and District Court litigation. This includes corporate and partnership audits, FBAR and captive insurance issues, defense of trust fund recovery penalties for employment taxes, innocent spouse relief, collection matters and many others.

Clients appreciate Brian’s knowledge of IRS practice and procedure, especially in formulating strategies for addressing clients’ tax issues. Oftentimes the IRS bureaucracy presents a variety of ways to address a problem, some more likely to succeed than others. Brian leverages his significant IRS experience to craft a unique solution for each client.

Brian also regularly counsels clients on a variety of domestic and international tax planning issues, including U.S. citizens with undisclosed foreign financial assets.

Brian was previously a Trial Attorney with the Tax Division, U.S. Department of Justice where he represented the IRS and the United States in federal courts across the country. He litigated several of the government’s largest and most significant tax shelter cases involving hundreds of millions of dollars in taxes and other cases involving summons enforcement, trust fund recovery penalties, return preparer penalties and injunctions, property valuation, fraudulent transfers, and the treatment of taxes in bankruptcy. This gives Brian a unique view into how the IRS and the U.S. DOJ evaluate, litigate and settle cases, and he leverages this inside experience for his clients.

Brian is board-certified as a specialist in tax law by the Florida Bar. He is also a triple Gator.

Brian@FMHlegal.com
☎  813.682.1720

Practice Areas

  • Tax litigation
  • International tax
  • Tax Law

Education

  • University of Florida
    • J.D. (2001)
    • M.S., Electrical Engineering (2001)
    • B.S., Computer Engineering (1997)

Admissions

  • Florida, Illinois
  • U.S. Tax Court
  • U.S. District Court, Middle District of Florida
  • U.S. Supreme Court

Distinctions

  • Litigation and Controversy – Tax and Tax Law (2018 – present), Best Lawyers in America
  • Super Lawyer, Tax: Business (2018-21) | Rising Star, Tax (2014-16), Florida Super Lawyers
  • Florida Trend’s Legal Elite, Listed for Tax (2018)
  • Outstanding Attorney (2009, 2007), U.S. Department of Justice, Tax Division

Professional Associations

  • Florida Bar, Tax Section
    • Executive Committee (2014 – present)
  • Florida Bar, Federal Court Practice Committee
    • Organization position (Jul 2013 – Jun 2019)
    • Chair (2016-2017)
    • Vice-Chair (2015-2016)
  • Hillsborough County Bar Association, Tax Section, Co-Chair, 2014-2015

Publications & Presentations

  • The Florida Bar, Tax Section, Webinar, Speaker, “Strategies for Defending Against Common IRS Penalties,” May 13, 2020
  • Lex Mundi Blockchain Whitepaper Series, Author, “Bitcoin, ICOs and the IRS – U.S. Tax Issues,” February 2019
  • Tax Management Estates, Gifts, & Trusts Journal, Co-Author, “Foreign Trusts: It’s All Fun and Games Until Someone Gets Caught,” Vol. 43, No. 6, November 8, 2018
  • Tax Management International Journal, Co-Author, “Foreign Trusts: It’s All Fun and Games Until Someone Gets Caught,” Vol. 47, No. 10, October 12, 2018
  • LISI International Tax Planning Newsletter #26, Co-Author, “Foreign Trust Reporting: You Can Run but You Can’t Hide,” July 26, 2018
  • Professional Education Broadcast Network, Speaker, “Estate and Gift Tax Audits,” July 23, 2018
  • The Florida Bar Tax Section, Speaker, “Tax Cuts and Jobs Act: Individual Income Tax Issues,” March 21, 2018
  • Probate & Pumpernickel Series, Speaker, “IRS Enforcement and Compliance Update,” Naples, Florida, March 20, 2018
    The Florida Bar Tax Section, Speaker, “An Overview of Tax Procedure,” February 7, 2018
  • The Florida Bar Tax Section, Speaker, “Introduction to the 2017 Tax Cuts and Jobs Act,” January 4-5, 2018
  • Probate and Pumpernickel Series, Speaker, “IRS Enforcement Update,” Orlando, Florida; October 10, 2017
  • NYU 9th Annual Tax Controversy Forum, Speaker, “But It’s Not My Fault! Developing a Robust, Reasonable Cause Defense to Penalties,” June 16, 2017
  • The Frances D. Sheehy Memorial Advanced Tax Procedure Seminar, Speaker, “Tax Enforcement, Settlement Procedures, and the Division of Authority,” May 5, 2017
  • The Florida Bar Tax Section, Federal Tax Division, Speaker, “Tax Procedure Review for the Board Certification Exam,” February 8, 2017
    Probate and Pumpernickel Series, Speaker, “Current Federal Tax Issues in Probate & Estate Administration,” Sarasota, Florida; November 16, 2016
  • The Florida Bar Tax Section, Young Lawyers Division, CLE Teleconference, Co-Speaker, “Tax Procedure Review for the Board Certification,” December 2015
  • LISI Asset Protection Planning Newsletter #2424, Co-Author, “Summaries of Presentations from the 2016 Florida Tax Institute,” June 15, 2016
  • Probate and Pumpernickel Series, Speaker, “Current Federal Tax Issues in Probate & Estate Administration,” Naples, Florida; March 15, 2016
    Hillsborough County Bar Association, Tax Law Section CLE, Co-Presenter, “Ethics of Representing the Low Income Taxpayer,” November 13, 2015
  • 7th Annual NYU Tax Controversy Forum, Panelist, “Contesting Tax Penalties,” June 5, 2015
  • The Florida Bar Journal, Volume 89, No. 6, Author, “Continuing Trends in State Tax Litigation: Nexus and Challenging State Tax Laws in Federal Courts,” June 2015
  • The Florida Bar Tax Section, Young Lawyers Division, CLE Teleconference, Co-Speaker, “To Pre-Pay or Not to Pre-Pay: Considering Tax Court v. District Court Litigation,” March 11, 2015
  • Lawyer, Hillsborough County Bar Association (HCBA), Co-Author, “Tax Issues for Marijuana Businesses,” January/February 2015
  • Lawyer, Hillsborough County Bar Association (HCBA), Author, “IRS Modifies Offshore Voluntary Disclosure Program,” September/October 2014
  • Hillsborough County Bar Association, Tax Law Section CLE, Co-Presenter, “International Issues of U.S. Taxation: FBAR, FATCA, OVDP, etc.” September 23, 2014
  • The Florida Bar Tax Section 2013-2014 Organizational Meeting, Speaker, “Ullman Year in Review,” July 5, 2013
  • 5th Annual NYU Tax Controversy Forum, Panelist, “This isn’t Your Grandfather’s Tax Controversy Business Anymore: Recent Developments in Enforcement, Audit, and Privilege Issues,” June 7, 2013

360° Tax Law Expertise

Micah Fogarty

Micah Fogarty 

Matt Mueller

Matt Mueller

Brian Harris

Brian Harris