Paul Butler is an experienced and accomplished civil tax litigator. During his more than 20 years of experience with the IRS Office of Chief Counsel and the U.S. Department of Justice Tax Division, Paul handled and supervised the litigation of cases involving complex tax transactions and structures, the organization and promotion of international and domestic tax shelters, the Administrative Procedure Act, John Doe summons enforcement, the Foreign Account Tax Compliance Act, conservation easements, and international reporting requirements and related penalties, including suits to collect willful penalties for failure to file reports of foreign bank accounts (FBARs).
Most recently, Paul served as a trial attorney in the Department of Justice’s Tax Division Civil Trial Section, Western Region, appearing in US District Courts and Bankruptcy Courts throughout the Mountain and Pacific time zones. Prior to his work at the Department of Justice, Paul served for 16 years in the Office of Chief Counsel for the Internal Revenue Service, where he was responsible for providing, supervising, and managing legal advice to IRS audit teams who were examining some of the largest financial services institutions, utility companies, and manufacturers in the Mid-Atlantic. Paul also supervised teams of attorneys conducting tax court litigation on issues of excise taxes and large corporate bankruptcies, and complex income tax shelters and tax credit schemes. Earlier in his career, he served as an instructor to other government lawyers on foreign trusts and foreign account information gathering. He also supported Department of Justice Senior Litigation Counsel in the conduct of litigation of some the largest Tax Analyst FOIA litigation cases in the late 1990s involving requests for Field Service Advice and documents exchanged within international tax coordination organizations such as the Group of Four (G-4) and the Pacific Area Taxing Authorities (PATA).
In addition, Paul was specially assigned to assist in the IRS response to the inquiries of four separate congressional committees and the associated litigation involving alleged improprieties within the determination process employed by the IRS for reviewing the tax exempt applications of politically active entities. During that two-year assignment, he conducted internal investigations, interviewed dozens of congressional witnesses, and coordinated the production of hundreds of thousands of documents responsive to congressional subpoenas.
Paul is a senior member of the J. Edgar Murdock Inn of Court at the U.S. Tax Court, served as an instructor and the lead instructor numerous times at the Office of Chief Counsel week-long trial advocacy courses for government attorney of varying experience levels, and has been a panelist and speaker at various meetings and conferences of the American Bar Association, Tax Section.
Mr. Butler earned his J.D. from the University of Maryland School of Law and his B.B.A. in Finance (minor in Political Science) from the Sellinger School of Business at Loyola University. He received a Department of Justice Special, Commendation Award for his work on a week-long jury trial, the Office of Chief Counsel A.A. Ballantine Award for National Coordination for combatting tax credit abuse in the U.S. insular territories, as well as numerous Office of Chief Counsel annual performance awards for excellent legal service to the IRS.
- United States Department of Justice (Civil Trial Section, Western Region), Trial Attorney, January 2015 – November 2018
- Office of Chief Counsel to the IRS (Large Business & International Division), Associate Area Counsel, Washington, DC, March 2011 – January 2015
- Office of Chief Counsel to the IRS (Small Business/Self-Employed Division)
- Deputy Area Counsel, Philadelphia, PA, March 2008 – January 2011
- Associate Area Counsel, Boston, MA, August 2006 – March 2008
- Senior Trial Attorney, Washington, DC, April 2001 – August 2006
- Office of Chief Counsel to the IRS (National Office, Disclosure and Privacy Law), Docket Attorney, October 1998 – April 2001
- Panelist, "Statutes of Limitations in Tax Litigation: Friend or Foe?" 2019 ABA Taxation Section May Meeting, Washington, D.C. (May 9, 2019)
- Panelist, "Connecting the Dots - Managing Privilege in an Interconnected World," Tax Executives Institute, Washington, D.C. (April 2, 2019)
- Panelist, "Ethical Issues in Federal Tax Practice – The Government Perspective," 2019 ABA Taxation Section Midyear Meeting, New Orleans, LA (January 18, 2019)
- Panelist, "IDRs vs. FDRs – IRS Tools to Discover Taxpayer Documents at Home and Abroad," 2019 ABA Taxation Section Midyear Meeting, New Orleans, LA (January 18, 2019)