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.

Presentations & Speaking Engagements

  • “Measuring Your Audit Risk,” IRS Audit Issues for the Food & Beverage Industry, 2012.
  • “Divorce: When a Spouse or Former Spouse Files Bankruptcy,” Strafford Webinar, 2012.
  • “Selected Tax Issues for the Real Estate Investor,” Real Estate Tax Issues Seminar, 2012.
  • “A Smorgasboard of Employment Tax Issues,” Georgia Tax Forum, in Atlanta and Savannah, Georgia, 2012.
  • “IRS Audit Issues and Hot Topics,” Georgia Tax Forum in Savannah, Georgia, 2012.
  • “Eggshell Audits,” North Atlanta Tax Council, 2010.
  • “The Codified Economic Substance Doctrine – A Congressional
  • Attempt at Clarification,” Institute of Georgia Institute of Continuing Legal Education Seminar, 2020 entitled “Hot Tax Topics for Business Attorneys.”
  • “Employment Tax Liabilities of Exempt Organizations,” Atlanta Bar Association’s Pro Bono March Madness, 2010.
  • “Representing the Criminal Tax Target through DOJ Conference: Try to Keep it Civil,” Georgia Institute of Continuing Legal Education Seminar, 2010 entitled “Civil and Criminal IRS Tax Fraud Initiatives.”
  • “Tax Traps for the Sandwich Generation,” Georgia Bar Meeting, Amelia Island, Florida, 2010.
  • “Strategies in Federal Tax Litigation,” Georgia Institute of Continuing Legal Education Seminar, 2004 and 2005 entitled “Dealing with the IRS.”
  • “Taxation of Attorney Fees and Settlement Awards, Tax Shelter Update and Attorney Client Privilege Issues for the Estate Planner,” 51st Annual Estate Planning Institute, 2006.
  • “Hot Audit Issues,” Georgia Tax Forums sponsored by the Georgia Society of CPAs, Atlanta, Georgia, 2002 and Savannah, Georgia, 2002.
  • “Tax Scams: How to Protect Clients Against Too Good To Be True Tax Planning,” Institute of Continuing Legal Education Seminar, 2002 entitled “Tax Issues for the Non-Tax Practitioner.”
  • “Litigating A Civil Case Tax,” Georgia Institute of Continuing Legal Education Seminar, 2003 entitled “Dealing with the IRS.”
  • “Civil and Criminal Employment Tax Audits,” DeKalb Chapter of the Georgia Society of CPAs, 2002.
  • “Civil and Criminal Employment Tax Audits,” North Atlanta Tax Council, 2002.
  • “Does Your Client Owe Back Taxes?,” Atlanta Bar Association Luncheon, 2002.
  • “Overview of the Jobs and Growth Tax Relief Reconciliation Act of 2003,” Southeastern Accounting Show, 2003 entilteld (“Recent Developments in Federal Income Taxation”)
  • “Preserving the Work Product and Attorney Client Privilege in Tax Matters without Alienating Your Client’s Other Advisors,” ICLA of Georgia, 2003, entitled “Emerging Issues in Tax Law.”
  • “Judicial and Legislative Highlights for 2001,” Chamberlain Hrdlicka 16th Annual Tax and Business Planning Seminar, 2001.
  • “Gambling on Employee or Independent Contractor Status – Criminal
  • Investigations Division Raises the Stakes,” Georgia Institute of Continuing Legal Education Seminar, 2001 entitled “Emerging Tax Issues for the Non-Tax Practitioner.”
  • “New Tricks Old Dogs: The Changing Look of Negotiations with the IRS,” North Atlanta Tax Council and the Atlanta Chapter Of the Tax Executive’s Institute, 2000.
  • “Behind the Examination: The Struggle Between Government Power and
  • Taxpayer Rights,” Chamberlain Hrdlicka 15th annual Tax and Business Planning Seminar, 2000.
  • “Eggshell Audits: Handling the Examination When you Know the Eggs Are Rotten,” Chamberlain Hrdlicka 14th annual Tax and Business Planning Seminar, 1999.
  • “Selected Criminal Tax Issues for the General Practitioner,” Georgia Institute of Continuing Legal Education Seminar,1999 entitled “Emerging Tax Issues for the Non-Tax Practitioner.”
  • “The Good, The Bad, and the Ugly: Highlights and Lowlights of the
  • IRS Reform Bill,” Chamberlain Hrdlicka 13th Annual Tax and Business Planning Seminar, 1998.

Publications & Articles

  • "Corporate Tax Shelters: Is Every Generation Doomed to Repeat History?" Journal of Tax Practice & Procedure, Vol. 2, No. 3 June-July 2000
  • "Employment Tax Audits: both IRS Criminal and Civil Divisions Raise the Stakes" Journal of Taxation, Vol. 96, No. 6, June 2002
  • "Offshore Scheme Participants Can Get Onboard IRS Program" 70 Practical Tax Strategies 159 (March 2003).

Accolades