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Stephen Josey
Stephen Josey
Counsel — Tax
Counsel — Tax

Stephen Josey

Stephen Josey
New York

The Grace Building
1114 Avenue of the Americas
32nd Floor
New York, New York 10036

start quote symbolI regularly draw upon the skills and knowledge that I gained from government experience to assist clients in resolving their tax disputes efficiently and fairly.end quote symbol
Stephen Josey

Experience Highlights

  • (DOJ Criminal Investigation) – Represented an individual under criminal investigation by the United States Department of Justice Tax Division. During the investigation, the government issued a subpoena to a law firm that provided the client with both legal and accounting advice. Both the individual and the law firm challenged the subpoena leading to a multi-year privilege dispute that culminated in the Supreme Court of the United States granting certiorari in the matter, In re Grand Jury (Case No. 21-1397)

  • (DOJ Criminal Investigation) – Represented an individual under criminal investigation for promotion of “syndicated conservation easements”

  • Provided pre-litigation analysis for a large corporation on a potential multi-billion-dollar excise tax refund claim

  • Counseled large corporations on tax-related bankruptcy procedures, including tax claim priority and dischargeability of tax liabilities

  • Represented individuals and corporations under audit on issues involving substantiation of capital losses, eligibility for the qualified small business stock exclusion, and worker classification

  • Assists clients with navigating federal and state voluntary disclosure programs for issues including tax return non-filing, failing to report taxable income, and misclassifying workers for employment tax purposes

  • Represented clients in civil tax disputes before federal courts including a refund matter involving procedures for claiming foreign tax credits, defending a client in a suit to reduce estate tax liabilities to judgment and to hold the client – an estate executor – personally liable under the federal priority statute, and seeking to quash a summons that the IRS issued after receiving a foreign nation’s treaty request to gather the client’s United States banking records


  • Vanderbilt University Law School, J.D., 2012 (Vanderbilt Journal of Entertainment and Technology Law, Managing Editor)
  • University of Michigan, B.A. Economics and Organizational Studies with High Distinction, 2009
  • Trial Attorney, United States Department of Justice, Civil Division, 2016-2018
  • Trial Attorney, United States Department of Justice, Tax Division, 2013-2016
  • Judicial clerk to The Honorable J. Daniel Breen, U.S. District Court for the Western District of Tennessee, 2012-2013
  • The Best Lawyers in America© (BL Rankings, LLC), “Ones to Watch,” Litigation and Controversy – Tax (New York), 2022–2024
  • The Best Lawyers in America© (BL Rankings, LLC), “Ones to Watch,” Commercial Litigation (New York), 2021–2024
  • United States Department of Justice, Tax Division – Outstanding Attorney Award, 2016
  • Co-Chair, New York City Bar Association, Personal Income Taxation Committee
  • American Bar Association Section of Taxation
  • New York
  • District of Columbia
  • Tennessee
  • “Criminal Tax Investigations and Procedures: What Practitioners Need to Know”, New York County Lawyers Association, November 1, 2023 (co-speaker)
  • “Diversity in the Tax Bar – Reflections on Lessons Learned and the Path Forward,” Tax Notes, September 4, 2023 (co-author)
  • “An Inconvenient Truth About Remote Work – Connecticut’s Income-Sourcing Statute Needs Fixing,” CPA Journal, May/June 2023 Issue (author)
  • “Diversity in the Tax Bar,” Law Firm Anti-Racism Alliance Tax System Working Group Discussion Series, September 30, 2022 (co-panelist)
  • “Tips on Qualified Small Business Stock Exclusions, Law360 Tax Authority, July 27, 2022 (author)
  • Civil and Criminal Tax Penalties Committee Panel, ABA Section of Taxation, May 2021 Meeting (co-speaker)
  • “Accounting for Sales with Contingent Obligations: Methods and Considerations,” CPA Journal, May 2020 Issue (author)
  • “This is Privileged, Right? Attorney-Client Communications in the Tax Return Preparation Context,” Journal of Tax Practice and Procedure, October-November 2019 Edition (co-author)
  • “Give Me Back My Money: The Life of a Refund Suit,” IRS Representation Conference, November 21, 2019 (co-panelist)
  • “To Amend or not to Amend: Correcting Non-compliance on Past Returns,” Journal of Tax Practice and Procedure, February – March 2019 Edition (co-author)