Juliana D. Hunter
Juliana’s practice consists primarily of representing corporations, partnerships, and individuals in the resolution of tax controversies with the Internal Revenue Service and in the courts, as well as federal income tax planning.
Her tax controversy practice spans all phases of tax controversies, from audits to IRS Appeals to litigation in Tax Court and other federal courts, including appellate courts. She is also experienced in ERISA and employee benefit matters, including ERISA litigation and qualified plan correction issues. The following is a list of representative matters in which Juliana has assisted.
Experience Highlights
Obtained a full concession from IRS Appeals on a “hobby loss” issue under Code Section 183
Obtained a full concession from IRS in a dispute over a client’s right to relief under Code Section 1341
Obtained “Section 530” relief from IRS in connection with an employment tax dispute
Obtained a settlement of a production tax credit issue through IRS Fast Track Settlement program for the taxpayer
Estate of James A. Elkins, Jr., Deceased v. Commissioner, 767 F.3d 443 (5th Cir. 2014)
Credentials
- Stanford Law School, J.D., 2010 (Articles Editor, Stanford Law Review)
- Rice University, B.Mus. Music Performance and B.A. Philosophy, summa cum laude, 2007
- Selected to the Texas Rising Stars list, Super Lawyers (Thomson Reuters), 2017–2020
- Board Member: Houston Youth Symphony
- Texas
- U.S. Tax Court
- U.S. Court of Appeals for the Fifth Circuit
- U.S. District Court for the Southern District of Texas
- International Tax DevelopmentsApril 10, 2020
- Rankings & AwardsMarch 6, 2020
- International Tax DevelopmentsOctober 15, 2019
First published by Tax Notes Today
- Rankings & AwardsMarch 4, 2019
- Press ReleaseJanuary 22, 2019
- V&E+September 10, 2018
- Rankings & AwardsMarch 12, 2018
- “Migration of Intangibles in a Low-Value Environment,” Tax Executives Institute – Houston Chapter Tax School, Houston, Texas, February 24, 2017
- “Merger Agreements – Closing Conditions and Efforts Clauses in Uncertain Times,” Tax Executives Institute – Houston Chapter Tax School, Houston, Texas, February 24, 2017
- “Inversions: Are they still viable planning opportunities?,” International Roundtable, Tax Executives Institute – Houston Chapter, Houston, Texas, April 14, 2016
- “Elkins v. Commissioner: What Does the Case Mean for Fair Market Value of Fractional Interests?,” Spring Symposia of the American Bar Association Section of Real Property, Trust and Estate Law, April 30, 2015 (presenter)
- “Fee Disclosures: Duties, Risks and Best Practices,” ASPPA Benefits Council of Central Texas, December 10, 2013 (presenter)
- “Ongoing Challenges under the 408(b)(2) Fee Disclosure Regulations,” ASPPA Benefits Council of Central Texas, September 18, 2012 (presenter)
- “’No Taxation Without Representation’ in the American Woman Suffrage Movement,“ Stanford Law Review, 2010, as Juliana Tutt
News & Insights
First published by Tax Notes Today