Jonathan T. Amitrano

Partner
LL.M in Taxation, Tax Law Specialist

(714) 546-0445 x116 eFax: (949) 474-1058

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Jonathan T. Amitrano - Partner at The Law Offices of A. Lavar Taylor

Education

Master of Laws in Taxation (LLM), University of San Diego School of Law
Juris Doctor, University of Cincinnati
Bachelor of Arts, Geography, University at Buffalo

Awards & Certifications

Specialist in Taxation Law – California Board of Legal Specialization
ABA Nolan Fellow – 2024-2025
Southern California Super Lawyers Rising Star – 2015-2024
Vice Chair of the ABA Tax Collection, Bankruptcy and Workouts Committee – 2021-2024
Best Lawyers: Ones to Watch – 2023-2024
Up-and-Coming 25: Orange County Rising Stars – 2023-2024
Up-and-Coming 100: Southern California Rising Stars – 2024
Vice Chair of the California Lawyers Association Tax Procedure and Litigation Committee – 2019
Chair of the California Lawyers Association Young Tax Lawyers Committee – 2019
Orange County Top Tax Attorney Coast Magazine – 2015
Former OCBA Young Lawyer Division Community Outreach Committee – 2015
San Diego Top Young Attorney Nominee – 2013
Emerging Generation: Top 25 in their 20’s Finalist – 2013
University of San Diego Carr Ferguson Fellow – 2011
University of Cincinnati Corbin Prize for Leadership and Taxation – 2010

Overview

Jonathan T. Amitrano has extensive background in federal and state tax controversy and is a Certified Specialist in taxation law by the California Board of Legal Specialization. Jonathan has significant experience representing both individuals and businesses before various tax agencies, including the Internal Revenue Service (IRS), Franchise Tax Board (FTB), the Employment Development Department (EDD), and the California Department of Tax and Fee Administration (CDTFA).

Jonathan regularly represents clients from around the world in complex federal and state tax controversy matters. These include matters relating to civil tax audits, trust fund disputes, offshore and domestic disclosure matters, promoter investigations, appeals hearings, and tax matters pending before various Courts. As a firm that exclusively handles tax controversy matters, Jonathan and his team are able to navigate the largest and most complex tax controversy disputes. Where a tax matter cannot be resolved administratively, Jonathan regularly litigates tax matters before various Courts and tribunals, including the U.S. Tax Court, California Office of Tax Appeals, California Superior Court, U.S. District Court, U.S. Bankruptcy Court, and the U.S. Court of Appeals.

Outside of the civil arena, Jonathan also regularly represents clients facing Federal criminal tax charges. At the State level Jonathan has handled numerous California criminal tax cases, including cases brought by the California TRUE Task Force.

Jonathan has been instrumental in protecting his clients, their businesses, and their livelihoods. He understands the sensitive nature of the cases he handles, and he seeks to resolve these matters as quickly and quietly as possible, with the best possible resolution for his clients.

Jonathan regularly presents on various tax controversy subjects throughout the United States and was named a 2024-2025 John S. Nolan fellow by the American Bar Association. He is a Professor at the Dale E. Fowler Chapman School of Law, where he has taught Federal Tax Research and Writing since 2018. Jonathan also previously served as a Professor at University of California San Diego where he taught Tax Controversy.

Jonathan currently serves as the Vice Chair of the American Bar Association Tax Collection, Bankruptcy & Workouts Committee. He previously served as the chair of the California Lawyers Association Young Tax Lawyers Committee, and as Vice Chair of the California Lawyers Association Tax Procedure and Litigation committee. Jonathan has been recognized as a Southern California Super Lawyers Rising State for the past 10 years and is also listed as a Best Lawyers: Ones to Watch.

Publications & Speaking Engagements

PUBLICATIONS

Extend Collection Due Process Deadlines – Here’s How, Tax Notes, June 26, 2024.
Amending and Aligning the IRS International Penalty Structure, Tax Notes, October 2, 2017.
The Tax Court Considers Procedural Requirements for Penalty Assessments, California Tax Lawyer, 2017.
Equitable Tolling and Title 26, California Tax Lawyer, 2015.
IRS Criminal Investigation Division Announces New Policy on Structuring Cases, California Tax Lawyer, 2014.

SPEAKING ENGAGEMENTS

Tax and Family Law Crossover – Innocent Spouse, California Lawyers Association Taxation Section Annual Meeting, November 7, 2024.
The Power of Metadata: Challenging Penalties under Section 6751(b), American Bar Association Taxation Section Mid-Year Meeting, January 19, 2024.
Gig Economy Taxation, American Bar Association Taxation Section Mid-Year Meeting, January 19, 2024.
The Long and Confusing History of the Use of Section 6751(b) to Defend the IRS Assertion of Penalties, California Lawyers Association Taxation Section Annual Meeting, November 3, 2023.
Tax Misinformation, Accuracy-Related Penalties, and Establishing Reasonable Cause in the Age of Social Media, American Bar Association Taxation Section Fall Meeting, October 20, 2023.
Nuts and Bolts of Tax Litigation, Americana Bar Association Taxation Section webinar, September 6, 2023.
California Tax Agencies Unlocked, California Society of Enrolled Agents, August 31, 2023.
Controversy Panel: Top 5 Mistakes Made in Tax Court Cases, RJS Law Tax Controversy Institute, July 28, 2023.
Are you on record? Don’t fall trap to the record rule, American Bar Association Taxation Section May Meeting, May 5, 2023.
Combating Tax Misinformation from Social Media, American Bar Association Taxation Section Mid-Year Meeting, February 10, 2023.
Technological Advancements in Tax Practice and the Impact of the Inflation Reduction Act on the IRS’s Capabilities and Service, Americana Bar Association Taxation Section webinar, December 6, 2022.
California Tax Agencies Unlocked, California Society of Enrolled Agents, November 8, 2022.
Technological Advancements in Tax Practice and the Impact of the Inflation Reduction Act on the IRS’ Capabilities and Service, American Bar Association Taxation Section Fall Meeting, October 14, 2022.
Tax Collection and Federal Litigation Updates, American Bar Association Taxation Section May Meeting, May 13, 2022.
Form Audits to Collections, and How to Resolve a Liability in Dispute, California Society of Tax Consultants Inland Empire, November 17, 2021
IRS Audit: From Exam to Tax Court, California Lawyers Association Young Tax Lawyers, April 30, 2021
IRS Audits, Collection, and the Role of Collection Due Process Hearings, California Society of Enrolled Agents San Fernando Valley, September 9, 2019
The Role of Form 4340 in Tax Litigation, American Bar Association Section of Taxation Midyear Meeting, January 18, 2019
Dealing with IRS Summonses: 20 Questions, California Society of CPA’s Hollywood/Beverly Hills Discussion Group, September 28, 2018
Audit Representation, California Society of Tax Consultants Orange County South Chapter, June 26, 2018
Ethics and Circular 230, California Society of Enrolled Agents South Bay Chapter, June 19, 2018
Handling Payroll Tax Collections Cases and Related Advocacy for Your Client, California Society of CPA’s Hollywood/Beverly Hills Discussion Group, December 8, 2017
Ethical Considerations for Tax Professionals, Inland Empire Chapter of the California Society of Tax Consultants, August 16, 2017
Potholes and Pitfalls – Ethical Considerations for Tax Practitioners, Orange County Chapter of the California Society of Tax Consultants, June 14, 2017
Audit Representation and Controversies, Palomar Chapter of the California Society of Enrolled Agents, August 17, 2016
Tax Representation: From Audits to Collection, Orange County Chapter of the California Society of Tax Consultants, September 14, 2016
How to Represent Your Clients Before the Taxing Agencies, North San Diego Chapter of the California Society of Tax Consultants, October 13, 2016
Tax Audits and Challenging an Assessment Post Audit, Inland Empire Chapter of the California Society of Tax Consultants, October 19, 2016
Coordination of the BOE and FTB Voluntary Disclosure Programs and the Conflicting Registration Requirements of the Two Programs, Sacramento Delegation, February 5, 2016
Audit Red Flags – Know When to Charge and When to Retreat, Orange County Chapter of the California Society of Enrolled Agents, November 17, 2015
Overview of Federal Practice, Bridging the Gap Program, July 11, 2015
Ethics: Ethical Issues in Tax Practice and Procedure, 2015 Annual Income Tax Seminar, June 26, 2015
Keep Out of Trouble and Run an Efficient Business, Continuing Legal Education Seminar San Diego Law Library Panelist, August 28, 2014
Appeals, Collections, & Offshore Issues, Southern California Tax Professionals, July 9th, 2014
Audit Red Flags and FTB Audit and Collection Issues, CSEA San Diego Chapter, November 12, 2013
State and Federal Audit Red Flags, California Society of Tax Consultants North County, July 11, 2013
IRS Fresh Start Program, Continuing Legal Education Panelist, December 6, 2012
IRS Collections, Employment Tax Issues & IRS Criminal Investigations, CPA Educational Seminar Panelist, November 7, 2012

Reported Cases

Couterier v. Comm’r, 162 T.C. 4 (2024)
Couterier v. Comm’r, T.C. Memo 2024-6 (2024)
Delponte v. Comm’r, 158 T.C. 159 (2022)
U.S. v. Boyd, 991 F.3d 1077 (9^th Cir. 2021)
Reynolds v. Comm’r, T.C. Memo 2021-10 (2021)
Jones v. Comm’r, T.C. Memo 2019-139 (2019)
Our Country Home Enters. v. Comm’r, 855 F.3d 773 (7^th Cir. 2017)
Keller Tank Servs. II v. Comm’r, 854 F.3d 1178 (10^th Cir. 2017)
Iames v. Comm’r, 850 F.3d 160 (4^th Cir. 2017)