Lawrence (Larry) Sannicandro focuses his practice on federal and state tax controversies, including representation in audits, administrative appeals, collection matters, summons proceedings, criminal tax investigations and prosecutions, and litigation in the United States Tax Court, federal district and appellate courts, and state tax tribunals. He has extensive experience providing tax-related advice with respect to original tax return reporting positions on a broad range of substantive tax issues, amending tax returns, filing and litigating claims for refund, challenging civil tax penalties, reporting foreign assets and income, and making voluntary disclosures.
Drawing on his unique experience as a former estate and gift tax attorney for the IRS, Larry is particularly well-versed in estate and gift tax planning techniques, as well as the valuation of closely held businesses, and defending those techniques and valuations in disputes with tax authorities. He also counsels clients on all facets of estate, business, and tax planning, including the formation, operation, transfer, and termination of business entities.
Larry is a member of the Internal Revenue Service Advisory Council (IRSAC) and a fellow of the American College of Tax Counsel. He serves the American Bar Association (ABA) Section of Taxation as a vice chair of the Court Procedure and Practice Committee as well as a member of the Appointments to the Tax Court Committee. He was also a past Chair of the ABA Section of Taxation’s Committee on Tax Collection, Bankruptcy and Workouts. On behalf of the Tax Section, he has drafted comments to Congress, the IRS, the Treasury Department, and the United States Tax Court on a wide range of tax issues, such as reforming the procedures for auditing and litigating against partnerships and the need to adopt a voluntary disclosure program for unreported cryptocurrency transactions.
Education
- M., Georgetown University law Center
- D., University of Florida Levin College of Law
- MBA, Binghamton University
Tax Management Portfolios™
-
IRS National Office Procedures — Rulings, Closing Agreements (Portfolio 621)
This Portfolio discusses the procedures for requesting rulings, determination letters, technical advice, closing agreements, and other types of guidance from the IRS.