Vivian Hoard limits her practice to civil and criminal tax controversy and tax litigation. Her clients include small businesses and their owners, publicly traded companies, professional athletes, and entertainers. Ms. Hoard consults with accounting firms during audits to help them and their client’s understand their procedural options for resolving the dispute. Ms. Hoard has successfully settled civil tax controversies involving many varied tax issues including tax shelter/sham transactions, Section 29 energy credits, conservation easements, deductibility of illegal payments under section 162, the civil fraud penalty, hobby loss issues, worker classification, trust fund liability, innocent spouse claims, passive loss issues, and much more. Ms. Hoard has also successfully represented taxpayers targeted for criminal prosecution by convincing justice department attorneys the case should be treated as a civil matter rather than a criminal matter. Ms. Hoard also regularly appears on behalf of her clients in the United States Tax Court, District Court, and IRS Appeals. While most Tax Court cases are resolved by settlement with the IRS office of Appeals, other cases must be tried before the United
States Tax Court.