Josh O. Ungerman, J.D., CPA
Mr. Ungerman specializes in tax controversies in addition to tax, business, estate and charitable planning. He has been involved with both domestic and international tax disputes in the United States Tax Court, the United States District Courts, and the United States Circuit Courts. The tax matters in which Mr. Ungerman is involved are typically very complex from both a factual and legal perspective. These matters often require legal and accounting skills. Mr. Ungerman is also a Certified Public Accountant.
Mr. Ungerman has been quoted on tax and estate matters in Forbes, Bloomberg, The BNA Daily Tax Report, and Tax Analysts-Tax Notes. The Chambers USA Guide describes Mr. Ungerman as “Incredibly dedicated: He lives and breathes his client’s problems,” and further reports, “If I knew somebody in a difficult position with the IRS, I’d definitely call Josh.” Chambers USA describes the firm as a boutique which “draws resounding praise for its ‘fantastically capable litigators,’ who have extensive tax and white-color crime litigation experience and expertise,” and “frequently advises on criminal, income, and estate and gift tax matters.”
Mr. Ungerman is a frequent speaker on tax topics including exams, IRS estate tax strategies, tax shelter defense, recent tax legislation, IRS criminal tax investigation techniques, and state tax controversy issues. Mr. Ungerman is quoted in BNA's Daily Tax Report on August 15, 2011 in an article titled, "Taxpayers Fear Disclosing Offshore Assets As Deadline Approaches, Practitioners Say." He is also quoted in an article, “Applying Mayo Federal Circuit Defers to Controversial Overstated Basis Regulation” by Jeremiah Coder in Tax Notes by Tax Analysts, March 14, 2011 and also in the article, "Seventh Circuit Overturns Tax Court on Gross Income Omission" by Jeremiah Coder in Tax Notes by Tax Analysts, January 31, 2011. Alan K. Davis and Josh O. Ungerman published an article, "An Untaxing Year" in the December 20, 2010 Texas Lawyer, Vol. 26., No. 38. Josh O. Ungerman is also quoted in an article, "IRS Withdraws 'John Doe' Summons Against UBS Over Tax Fraud Allegations" by Daniel Pruzin (Geneva) and Alison Bennett (Washington) in the Daily Tax Report, November 17, 2010. Mr. Ungerman was quoted in three Tax Practice articles (published weekly by TaxAnalysts) on May 24, 1010, “IRS Undeterred After Tax Court’s Intermountain Decision”, April 12, 2010, "IRS Help for Struggling Taxpayers Contrasts With Enforcement Push" and on April 5, 2010, "Federal Circuit Overturns Penalty Determination in Jade Trading". Mr. Ungerman is also quoted in an article published on taxanalyst.com entitled, "Swiss Agree to Expedite Processing of 4,450 UBS Accounts Under Treaty Request" by David D. Stewart on August 20, 2009. He was also quoted in an article on bloomberg.com entitled, "Billionaire Tax Felon Says UBS Lied in Pledge to Report to IRS" by David Voreacos on June 9, 2009. Another article he was quoted in was published on moneylaundering.com entitled, “Uptick in Tax Evasion Disclosures Mean More Bank Investigations, Say Attorneys" by Matt Squire on November 5, 2008.
Mr. Ungerman is quoted in the book, “The Cheating of America: How Tax Avoidance and Evasion by the Super Rich Are Costing the Country Billions–and What You Can Do About It" by Charles Lewis and Bill Allison and the Center for Public Integrity. Mr. Ungerman was admitted to practice in Texas in 1990.
