Toledo Tax Controversy Clinic
at the University of Toledo College of Law
Mail: P.O. Box 12458, Toledo, Ohio 43606
Physical: 1825 W. Rocket Drive, Toledo, Ohio 43606
Tel. 419-684-TTCC (8822) | Fax. 419-685-9080
The Toledo Tax Controversy Clinic provides assistance to taxpayers in handling disputes with the Internal Revenue Service. In order to give law students valuable experience in handling actual tax cases, the Clinic offers free representation to taxpayers who are involved with IRS audits, appeals, and collection matters. In certain cases, the Clinic represents taxpayers before the United States Tax Court. The Clinic negotiates and resolves contested matters with the IRS. Representation is offered to taxpayers who could not otherwise afford representation and also to a limited number of taxpayers in cases of particular educational merit, where the fee which would normally be charged by a tax practitioner could be expected to equal or exceed the amount of tax in controversy.
The Clinic is staffed by law students who are trained in tax law and supervised by the Clinic Director of the Toledo Tax Controversy Clinic who is a full-time practicing tax attorney and faculty member. Cases are accepted only when the proposed adjustments by the IRS are susceptible to further factual development or legal argument. The Clinic not only gives students significant attorney/client experience, it also fulfills the need of underrepresented taxpayers for free and competent legal representation.
The Toledo Tax Controversy Clinic receives referrals from various sources including attorneys, accountants, and the IRS. The IRS and U.S. Tax Court may send notices to taxpayers explaining services of the Clinic.
The Toledo Tax Controversy Clinic represents taxpayers in their disputes with the Internal Revenue Service or who have filed or intend to file a petition with the United States Tax Court.
The Clinic’s primary objective is to represent taxpayers who would otherwise not be able to reasonably afford legal representation. Most of the clients do not have income and assets sufficient to hire an attorney or other representative. Other cases are accepted where the issues involved have educational merit and where the amount in controversy is sufficiently low, such that hiring a representative would clearly not be cost effective.
The Clinic also increases the efficiency of the judicial and administrative process, by providing taxpayers with high-quality legal advice on relevant tax procedures and substantive tax issues, as necessary for the effective resolution of tax matters.
The Clinic offers a free one-hour consultation to taxpayers. These consultations are offered to taxpayers who
The Clinic does not develop cases involving criminal tax charges brought by the U.S. Department of Justice, cases involving taxpayer participation in tax shelters, cases involving unreported foreign bank accounts and other foreign financial assets, or refund claims brought to the U.S. District Court or the Court of Federal Claims. The Clinic does not prepare tax returns for clients.
Christopher Bourell concentrates on helping taxpayers resolve their disputes with the IRS and with state and local tax authorities. He advises on examination strategy, defends taxpayers in appeals and litigation, and helps resolve tax collection matters.
Christopher understands the multi-layered complexities of federal and state tax law. He also understands the stress that tax disputes can bring, and is committed to helping each and every client resolve their issues in a timely and cost-effective manner. Christopher is a frequent speaker on federal and state tax law topics. He is enthusiastic about sharing his skills and knowledge to help clients and other tax professionals resolve difficult tax issues.
Christopher is a native of Austin, Texas. He attended the Liberal Arts Academy at Johnston High School, the Texas Academy of Mathematics and Science at the University of North Texas, and the Austin Graduate School of Theology. He attended law school at Southern Methodist University Dedman School of Law, where he was on the SMU Law Review and also earned membership in the prestigious Order of the Coif. Following law school, Christopher moved to New York City to begin his legal practice and continue his education in the Graduate Tax Program at New York University School of Law.
As a young man, Christopher was an Eagle Scout and continues to enjoy camping in the great outdoors. He is also fond of home improvement projects, live music, and serving his community.
New York University School of Law, LLM-Taxation 2004
Southern Methodist University School of Law, JD 2003
Austin Graduate School of Theology, BA 1999
PUBLICATIONS & PRESENTATIONS
• Tips from the Trenches: Litigating a CDP Case, panelist for the 6th Annual NYU Tax Controversy Forum, June 2014
• IRS Enforcement and Collections Process: Liens, Levies, and Seizures, CPE presentation for Baruch College Zicklin Tax Seminar, December 2013
• New York Residency Roundtable, CPE presentation for NYSSCPA Nassau Chapter All Day Tax Conference, December 2013
• Gambling: The Tax Man Always Wins, CPE presentation for NYSSCPA Nassau Chapter All Day Tax Conference, December 2013
• IRS Collection: Journey Through the Labyrinth, CPE presentation for the Long Island Tax Professionals Symposium, November 2013
• New York Residency Case Study, CLE presentation for the New York State Bar Association, Senior Lawyers Committee Fall Program, October 2013, CPE presentation for the NYSSCPA Brooklyn/Queens Chapter Annual Tax Conference, January 2013, and for the Long Island Tax Professionals Symposium, November 2012
• Tax Audits: How to Handle Them, How to Avoid Them, CPE presentation for the NCCPAP Nassau/Suffolk Chapter, Map Committee, December 2012
• Innocent Spouse Relief, CPE presentation for the NYSSCPA Nassau Chapter Half Day Tax Conference, October 2011, the NYSSCPA Brooklyn/Queens Chapter Annual Tax Conference, November 2011, and the NYSSCPA Staten Island Chapter Annual Tax Conference, December 2011
• Celebrity Tax Problems: When Tax Collection and New York Residency Matters Hit The Headlines, CPE presentation for the Long Island Tax Symposium, November 2011, and the NCCPAP Nassau Chapter Meeting, January 2011
• IRS Installment Agreements, half-hour CPE/CLE presentation for the Long Island University Tax Enforcement Update at the C.W. Post Campus, September 23, 2011
• IRS Collections Notices and Procedures, one-hour CPE presentation for accounting firm Raiche Ende Malter & Co., LLP, July 21, 2011
• New York Residency Update, one-hour CPE presentation for accounting firm Wild, Maney, Camera, & Resnick, LLP, March 17, 2011, and for accounting firm Raiche Ende Malter & Co., LLP, June 8, 2011
• Updated Audit Guidelines for New York Residency Disputes, article in the New York State Society of Certified Public Accountants, Nassau Chapter Newsletter, September 2010 (with Y. Cort & K. Tenenbaum)
• IRS Collections: Trust Fund Recovery Penalty, half-hour CPE presentation for the Long Island University Summer Tax Series at the C.W. Post Campus, August 27, 2010
• Texas Margin Tax, two-hour CLE/CPE presentation for the Oklahoma Society of Certified Public Accountants, December 4, 2008
• Interesting Developments in Like-Kind Exchanges, one-hour CLE presentation for the Austin Tax Study Group, May 20, 2008