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Brian R. Harris
Tax Controversy & Litigation | Fogarty Mueller Harris, PLLC
Brian R. Harris is a founding member and tax attorney at Fogarty Mueller Harris, PLLC, a boutique law firm specializing in tax controversy and white-collar litigation. He has extensive experience representing clients in various matters before the IRS, including audits, appeals, and litigation in U.S. Tax Court and District Court. His practice areas include corporate and partnership audits, FBAR issues, trust fund recovery penalties, and international tax planning, particularly for U.S. citizens with undisclosed foreign financial assets.12
Harris previously served as a Trial Attorney with the Tax Division of the U.S. Department of Justice, where he represented the IRS in significant tax shelter cases and other high-stakes litigation. This background provides him with unique insights into IRS and DOJ operations, which he leverages to benefit his clients.1
He is board-certified in tax law by the Florida Bar and has received multiple accolades, including recognition as a Super Lawyer and inclusion in Best Lawyers in America for his expertise in tax litigation.13 Harris holds a J.D. and an M.S. in Electrical Engineering from the University of Florida, along with a B.S. in Computer Engineering.1
In addition to his legal practice, he is actively involved in professional associations, including the Florida Bar's Tax Section, where he has held leadership positions.1 His LinkedIn profile can be found under the username "taxcontroversy" .4
Highlights
Well, this is sad news indeed. A couple friends and I were at the Allman Brothers Band's last run of shows at the Fillmore in 2014, and it was an incredible experience. I can't believe it's been ten years already.
Although Dickey was no longer with the band at that point, his legacy and music were definitely present and will continue to live on.
His unique and instantly recognizable style have been a huge influence to guitarists and in music for more than 50 years.
John Timar Stephen Harmon
The ATF has published a final rule defining who is "engaged in the business" of selling firearms and therefore needs a federal firearms license (FFL).
Under the rule, the analysis is whether one is selling predominantly to earn a profit, and as little as one sale can be enough to constitute a business.
The tax code contains a similar "for profit" test to distinguish between a business and a hobby. People generally cannot deduct losses from hobbies but they can from businesses.
I can't help but wonder about the possibilities for people to now deduct a wide range of firearms expenses because the ATF rule takes an expansive view of what constitutes a firearms business.
That is, has the ATF turned many people's hobby into a business?
Can a person have a profit motive and be engaged in a firearms business for ATF/FFL purposes but still lack a profit motive and not be in a business for IRS purposes?
These are interesting questions, at least for a tax attorney.
#taxcontroversy #IRS #taxes #ATF #FFL
