FacultyFaculty/Author Profile

Jenny L. Johnson Ware

Johnson Moore

Chicago, IL, USA


Jenny Louise Johnson handles complex tax disputes of signicant value for clients ranging from individuals to multinational corporations. She represents taxpayers in all stages of criminal and civil tax proceedings, including sensitive audits and examinations, IRS appeals, summons enforcement, search warrants, grand jury subpoenas, negotiated resolutions with the IRS and the Department of Justice, trials in federal district court and the U.S. Tax Court, sentencings and appellate litigation. She has successfully resolved disputes involving income taxes, estate and gift taxes, excise taxes, federal and state tax credits, employment taxes, and employee plan matters.

As a skilled trial lawyer with a sophisticated understanding of tax issues and extensive experience in each of the many forums where tax disputes get resolved, Ms. Johnson offers her clients creative and practical solutions that are customized to achieve the goals that are most important to each client. By bringing the perspective of a trial lawyer to the development of a case from the very beginning, she is often able to avoid the expense and uncertainty of protracted litigation and achieve a favorable settlement. When that is not possible, she is a powerful and seasoned advocate in the courtroom.

Ms. Johnson also routinely provides behind-the-scenes strategic counseling to clients and their other advisors on potential or existing tax-related disputes. For example, Ms. Johnson frequently works with high net worth individuals, families and their other advisors to identify potential audit risks and navigate enterprise examinations pursued by the IRS Global High Wealth Industry Group.

Ms. Johnson is an adjunct professor on the tax faculty at Northwestern Pritzker School of Law, currently teaching Investigation, Prosecution and Defense of Tax Crimes. She is also a frequent speaker and faculty member at both national and international professional conferences, and is in the upper echelon of nationally recognized tax litigators.

Ms. Johnson participated heavily in launching a Tax Court Calendar Call pro bono initiative in Chicago, representing low income taxpayers in front of the U.S. Tax Court. Partnering with the Center for Economic Progress, Ms. Johnson and her team developed a program to train attorneys and law students to represent low income taxpayers, and then appear in court to assist taxpayers who arrive for their required hearing without legal assistance.

Ms. Johnson lives with her three children in Western Springs, Illinois, where she is actively involved in her community.

Experience

Ms. Johnson’s recent experience includes:

serving as lead tax litigation counsel for a $3 billion estate with respect to an alleged $150 million estate and gift tax deficiency involving transfer of interests in a professional sports team

obtaining summary judgment for the taxpayer, defeating the government’s attempt to recover what it claimed was an erroneous tax refund, with the U.S. District Court repeatedly citing her arguments on complex aspects of the TEFRA regulations

trying three cases in the United States Tax Court involving alleged transferee liability in “Midco” intermediary tax shelter cases, including one victory and two cases currently awaiting final decision

successfully resolving a Global High Wealth Industry Group audit involving tax treatment of millions of dollars of state low income housing tax credits and various other complex issues at the individual and entity levels

winning a $5 million U.S. Tax Court trial by proving that the taxpayer materially participated in a business through activities that included entertaining potential investors

defending multiple clients in the bar and restaurant sector in criminal tax investigations and prosecutions, as well as the civil aftermath

negotiating a favorable resolution of an IRS audit involving executive compensation

representing multiple taxpayers in various claims for refund from IRS, including claims for penalty abatement and refunds relating to gifts and inheritances

supervising a team representing hundreds of taxpayers who are voluntarily disclosing to the IRS funds held in offshore bank accounts and related income tax liabilities

representing multiple plan sponsors who faced an IRS threat of disqualification of their qualified plans

convincing the IRS to abate over $1 million in penalties and interest resulting from misapplication of seized fund

Honors & Awards

Women of Influence Award Winner, Chicago Business Journal, 2014 Super Lawyer, Illinois Super Lawyers magazine, 2016

Rising Star, Illinois Super Lawyers magazine, 2013-2014

Chicago’s Rising Stars: 40 Under 40, The National Law Journal, 2013

Professional Activities

American Bar Association, Section of Taxation, Civil and Criminal Tax Penalties Committee, Vice Chair

American Bar Association, Real Property, Trusts and Estates Law Section, Income and Transfer Tax Planning Group, Tax Litigation and Controversy Committee, Chair

American Bar Association, Criminal Justice Section, White Collar Crime Committee

Harvard Law Society of Illinois, Board of Directors

Chicago Inn of Court

Speaking Engagements

Decision Documents and Their Aftermath, ABA 2016 Mid-Year Meeting, January 29, 2016

What’s New at Exam and Appeals, ABA National Institute on Criminal Tax Fraud and Tax Controversy, December 10, 2015

How to Get the Truth from Expert Testimony, ABA National Institute on Criminal Tax Fraud and Tax Controversy December 10, 2015

Aggressive IRS Audit Techniques – Tales from the Trenches, ABA 2015 Joint Fall CLE Meeting, September 19, 2015

Tax Litigation Developments from the Transfer Pricing Front, ABA 2015 Joint Fall CLE Meeting, September 18, 2015

The Limits of the Law: The Role of Compliance in the 21st Century, University of Cambridge Thirty- Third International Symposium on Economic Crime, September 8, 2015

Voluntary Disclosure and Swiss Secrets – Getting the Chocolate Out of the Wrapper, Chicago Society of Trust and Estate Practitioners Meeting, March 16, 2015

What’s a Young Tax Attorney to Do When...?, ABA Section of Taxation 2015 Midyear Meeting, January 29-31, 2015

Trial Strategies: Valuations, ABA National Institute on Tax Controversy, December 11, 2014

Global High Wealth Audits - A Game-Changing Strategy for the IRS, American Association of Attorney- Certified Public Accountants (AAA-CPA) Fall Meeting and Education Conference, November 5-8, 2014

The Trial Countdown, ABA Section of Taxation 2014 May Meeting, May 9, 2014

Ethical Issues Arising from Conflicts of Interest in Litigation, ABA Section of Taxation Meeting, Phoenix, Ariz., January 24, 2014

Ask the Experts: Top Civil Tax Practice Tips and Representation Strategies, ABA National Institute on Tax Controversy, Las Vegas, Nev., December 12, 2013

IRS Global High Wealth Industry and IRS Representation Tips, Chicago Bar Association, December 9, 2013

Information Gathering: IDRs, Summons, and Third Party Information and Tax Court Procedures: Pretrial Practices, ALI Handling a Tax Controversy: Audits, Appeals, Litigation and Collections, October 17-18, 2013

Elective Use of Demonstrative Exhibits and Summary Exhibits in Tax Cases, ABA Section of Taxation 2013 Fall Meeting, September 20, 2013

Ethical Issues Arising from Conflicts of Interest, Especially When Criminal Tax Charges are on the Horizon, ABA Section of Taxation 2013 Fall Meeting,September 20, 2013

Third Party Records and the Fifth Amendment: What Happened?, ABA webinar,August 20, 2013

The Handling and Mishandling of IRS Witnesses, ABA Section of Taxation 2013 May Meeting, May 11, 2013

Elective Use of Depositions at Trial, ABA Section of Taxation 2013 May Meeting,May 10, 2013

Our Clients in the Spotlight: The New IRS High Wealth Industry Group;, ABA Section of Real Property, Trust and Estate Law Spring CLE Symposia, , May 2-3, 2013

An Ethics Challenge: Identifying and Addressing Conflicts of Interest in Tax Controversies, ABA Section of Taxation Midyear Meeting, January 24, 2013

Update on Global High Wealth Industry Group Examinations, ABA Section of Taxation Midyear Meeting, January 24, 2013

Third Party Records and the Fifth Amendment: What Happened?, ABA Annual National Institute on Criminal Tax Fraud, December 6, 2012

The Global High Wealth Industry Group: A “Game-Changing” Move for the IRS and Practitioners, New York Society of Trust and Estate Practitioners, September 12, 2012

Don’t Blow It: Steps You Can Take to Bring Potential Whistleblowers to You Instead of to Court, Association of Corporate Counsel, Chicago Chapter, June 28, 2012

Representing Clients in Federal & State Criminal Tax Investigations: Defense Strategies & Prosecution Initiatives Every Attorney Needs to Know, New York City Bar, May 9, 2012

Resolving Disputes with the IRS: Techniques for Achieving a Favorable Post-Exam Settlement, ABA

Section of Real Property, Trust & Estate Law Annual Spring Symposia, May 3, 2012

Wage and Hour Compliance: Tailoring Your Program to Wage and Hour Risk in a New Era of Enforcement, Association of Corporate Counsel Compliance Committee Presentation, February 21, 2012

Tax Litigation: the Practitioner’s View, ABA National Institute on Criminal Tax Fraud, December 1-2, 2011

Where Do We Go From Here: A Comparison of Alternatives When You and the IRS Agree to Disagree, ABA Section of Taxation and Section of Real Property, Trust & Estate Law, Trust & Estate Division 2011 Joint Fall CLE Meeting, October 20-22, 2011

IRS Global High Wealth Industry Group: Compliance for High Wealth Individuals and Their Related Entities, Society of Trust and Estate Practitioners (STEP) Los Angeles, CA, October 4, 2011

Education

Harvard Law School, J.D., cum laude

Sewanee The University of the South, B.A., summa cum laude

Court Admissions

United States Court of Appeals for the Seventh Circuit

United States Court of Appeals for the Federal Circuit

United States Court of Appeals for the Eleventh Circuit

United States Tax Court

Illinois Supreme Court

United States District Court for the Northern District of Illinois, Trial Bar

United States District Court for the Eastern District of Wisconsin

United States District Court for the Eastern District of Michigan

Jenny L. Johnson Ware is associated with the following items:
Live Seminar  Live Seminar Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2018, Tuesday, May 01, 2018, Chicago, IL
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