Jack Taylor, an attorney and certified public accountant, has an active practice in tax controversy, including representation of taxpayers in both administrative proceedings and litigation. Over the past several years, Jack has handled numerous cases before the U.S. Tax Court, the U.S. Court of Federal Claims, federal district courts, and Texas district courts, including major tax cases tried in Washington, D.C., Houston and Los Angeles. A partner with Fulbright & Jaworski L.L.P. since 1985, he has served a wide range of clients, including high net worth individuals and companies in industries such as energy, real estate, telecommunications and professional services. 

According to Chambers USA 2011, Jack "consistently impresses clients with his 'ability to cut quickly to the key points and develop simple, cost-efficient case theories.'"

Mr. Taylor's recent and notable representation as lead counsel/attorney in charge includes the following:

Federal Tax Controversy - Examination/Investigation:

• Individual taxpayers across the country investing in stock option/restricted stock transactions
• Public company in the Midwest with respect to federal excise tax
• Accounting firms with respect to compliance with grand jury subpoenas
• Foreign and currency option transactions
• Intermediary company purchase and sale transactions
• Numerous high-wealth individuals with respect to foreign financial accounts and other arrangements
• Companies in Southwest with thousands of independent contractors with respect to federal employment tax worker classification issues
• Consulting firm headquartered in the Northeast specializing in tax advantaged transactions
• Exploration and production company headquartered in the Southwest, with respect to hedging transaction issues
• Attorney in the Southwest targeted by criminal tax investigation
• Dentist in the Southwest targeted by criminal tax investigation
• Physician in the Southwest targeted by criminal tax investigation
• Investor in the Southwest targeted by criminal tax investigation
• Corporate executive in California subjected to civil fraud investigation
• CEO of a public company headquartered in the Southwest, with respect to corporate governance/reimbursement issues

Federal Tax Controversy - Appeals Office:

• Public company headquartered in the Southwest, with respect to interest hybrid and travel & entertainment issues
• Individual taxpayer in the Northeast, with respect to participation in public company stock option transactions
• Real estate management and development firm headquartered in California, with respect to foreign entity transactions
• Public company executive in the Southwest, with respect to farming business issues
• Non-profit corporation in Texas with respect to federal employment tax issues associated with worker classification
• Refining company headquartered in the Midwest, with respect to excise tax issues
• New England family, with respect to stockholder purchase and sale agreement issues
• Cable television company headquartered in New England, with respect to reorganization issues
• Privately owned exploration and production company headquartered in the Southwest, with respect to reasonable compensation issues
• Estate of decedent in the Southwest, with respect to family limited partnership issue
• New England and Southwest residents, with respect to farming issues
• Closely-held company headquartered in the Southwest victimized by embezzlement, with respect to employment tax and collection-related issues
• Foreign owned real estate development company headquartered in the Southwest, with respect to effectively connected income issues

Federal Tax Controversy - Litigation:

• International labor union headquartered in Washington, D.C., in the United States Tax Court, with respect to UBTI issues
• Estate of a decedent in Louisiana, in the U.S. Court of Federal Claims, with respect to valuation and administration expense issues
• Industrial uniform provider headquartered in California, in the U.S. Tax Court, with respect to inventory issues
• Consulting firm, in New York federal district court, with respect to summons enforcement proceeding brought by government
• Real estate development and management company, in Southern California federal district court, with respect to summons enforcement proceeding brought by government
• Public company headquartered in the Southwest, in United States Tax Court, with respect to transactions with affiliated entities
• Multiple investment partnerships located in the Northeast, in United States Tax Court, with respect to currency option transactions with foreign-based entities
• Individuals investing in foreign currency option transactions, in Louisiana federal district court
• Individual taxpayers in New England, in United States Tax Court, with respect to stock sale transaction issues
• New England real estate developer, in United States Tax Court, with respect to capital gain versus ordinary income issues

Texas Property Tax Controversy - Appraisal District, Appraisal Review Board and Litigation:

• Public oil & gas major, with respect to refinery and foreign trade zone issues
• Sporting goods and apparel retailer, with respect to inventory issues
• Public utility headquartered in the Midwest, with respect to natural gas inventory issues
• Natural gas trader headquartered in the Northeast, with respect to interstate commerce issues
• Foreign-owned refinery, with respect to inventory issues
• Seven oil & gas majors, with respect to property tax fraud issues
• Natural gas trading company headquartered in the Southwest, with respect to inventory issues
• Utility company headquartered in the Midwest, with respect to inventory issues
• Cable television company headquartered in the Midwest, with respect to system valuation issues

Texas Tax Controversy - Administrative Law Judge and Litigation:

• Oil & gas major with respect to sales tax and franchise tax credit issues
• Brokerage house headquartered in California, with respect to sales tax on services issues
• Computer hardware manufacturer headquartered in California, with respect to sales tax on services issues
• Telecommunications company headquartered in the Northeast, with respect to sales tax, gross receipts tax and franchise tax issues
• Construction company headquartered in the Southwest, with respect to sales tax on services issues
• Foreign owned chemical manufacturer, with respect to sales tax on services issue
• Real estate development company headquartered in the Southwest, with respect to sales tax on services issues
• Refining company headquartered in the Northeast, with respect to sales tax on services issues
• Construction firm headquartered in Louisiana, with respect to successor liability issues
• Specialty construction company headquartered in the Southwest, with respect to sale tax on services issues
• Cable television company headquartered in the Northeast, with respect to franchise tax issues
• Brokerage firm headquartered in the Northeast, with respect to franchise tax issues and sales tax on services issues
• Environmental records firm headquartered in the Southwest, with respect to sales tax on services issue
• Defense contractor headquartered in the Southeast, with respect to sales tax on services issues
• Grocery chain headquartered in California, with respect to franchise tax issues
• Manufactured housing company headquartered in the Southeast, with respect to nexus issues

• American Bar Association
  • Section of Taxation
    • Committee on Court Procedure, Former Chair
• State Bar of Texas
  • Section of Taxation, Former Chair 
• National Institute for Trial Advocacy's week-long "Litigating in the U.S. Tax Court" program, Faculty Member
• SMU School of Law, "Advanced Federal Tax Litigation Conference," Faculty Member 
• University of Texas School of Law Annual Taxation Conference, Faculty Member

• Chambers & Partners USA, "America's Leading Lawyers for Business" (2004 - 2011)
• "Super Lawyer," Tax, Law & Politics (2007 - 2011)
• Best Lawyers in America, Tax (2006 - 2012)
• "Highly Recommended Individual," Which Lawyer? Yearbook, Tax, Practical Law Company (2009 - 2011)
• The Legal 500, Tax Controversy (2007 - 2010)

• Co-author, "IRS Gives Taxpayers Third Bite At The Apple; Announces Third Offshore Voluntary Disclosure Program," Fulbright Briefing, January 11, 2012
• Co-author, "Recent IRS Administrative Guidance on Economic Substance Leaves Many Unanswered Questions," Fulbright & Jaworski L.L.P. Briefing, September 17, 2010
• Co-author, "IRS Moves Closer to Requiring Corporations to Disclose Uncertain Tax Positions," Fulbright & Jaworski L.L.P. Briefing, September 9, 2010
• Co-author, "June 30, 2010 Deadline Approaching for Certain U.S. Persons Required to File Reports Relating to Foreign Bank Accounts," Fulbright & Jaworski L.L.P. Alert, June 15, 2010
• "IRS Plans to Oppose Privilege Claims for Engagements of Accountants by Attorneys," Fulbright & Jaworski L.L.P. Corporate Governance at a Glance, May 25, 2010
• "IRS Releases Draft Schedule and Instructions for Reporting Uncertain Tax Positions," Fulbright & Jaworski L.L.P. Corporate Governance at a Glance, May 17, 2010
• Co-author, "IRS Releases Draft Schedule and Instructions for Reporting Uncertain Tax Positions," Fulbright & Jaworski L.L.P. Briefing, April 23, 2010
• "IRS and the Department of the Treasury Release Guidance on Foreign Bank Account Reports,"  Fulbright & Jaworski L.L.P. Corporate Governance at a Glance, March 5, 2010
• Co-author, "IRS and the Department of the Treasury Issue FBAR Guidance," Fulbright & Jaworski L.L.P. Briefing, March 4, 2010
• "IRS About To Start Detailed Employment Tax Examinations," Fulbright & Jaworski L.L.P. Briefing, February 24, 2010
• Co-author, "IRS Announces New Broad Disclosure Requirements for Uncertain Tax Positions," Fulbright & Jaworski L.L.P. Briefing, January 29, 2010
• "IRS May Require Companies to Disclose Uncertain Tax Positions With Tax Returns," Fulbright & Jaworski L.L.P. Briefing, January 27, 2010
• Co-author, "DOJ Seeks Identities of Stanford Group's U.S. Investors," Fulbright & Jaworski L.L.P. Briefing, December 4, 2009
• Co-author, "IRS Announces Criteria Used to Determine Disclosure of Swiss Accounts," Fulbright & Jaworski L.L.P. Briefing, November 24, 2009
• Co-author, "IRS Extends Deadline For Voluntary Disclosure Program Until October 15, 2009," Fulbright & Jaworski L.L.P. Alert, September 22, 2009
• Co-author," Constructive Trust Imposition May Protect Assets of Defrauded Employers from IRS Claims," Fulbright & Jaworski L.L.P. Alert, June 26, 2009

He has lectured extensively at programs sponsored by the Tax Executives Institute, the American Bar Association's Section of Taxation, the Texas State Bar Association, and the Texas Society of Certified Public Accountants.

Some of his recent speeches in the tax litigation area include:

• Co-panelist, "Tax Litigation: The Practitioners' View," Annual National Institute on Criminal Tax Fraud and the First National Institute on Tax Controversy, December 2011
• Co-panelist, "Traps and Treasures: Effective Property Transfers Between Related Parties and Increased IRS Attention," Fulbright & Jaworski L.L.P. Web Seminar, August 24, 2011
• Co-panelist, "The Enhanced IRS Enforcement Regime," International Association of Drilling Contractors, International Tax Seminar, June 2011
• Co-panelist, "Offshore Financial Account Reporting: Risks & Penalties for Non-compliance," 2011 CPE Tax Expo, Houston Chapter of Texas Society of CPAs, January 2011
• "2010 Business Tax Update," LB&I - Houston TEI Joint Tax Conference, December 2010
• "Inventory in Transit - The Taxability Battle Continues: Texas," Institute for Professionals in Taxation 2010 Property Tax Symposium, November 2010
• "Increased Risk for Corporate Tax Departments from Changes in Federal Tax Enforcement," Greater Houston Partnership Texas Legislature Review and National Tax Summit, November 2010
• "Compliance with the New Schedule UTP Regime," TEI Woodlands Roundtable, November 2010
• "The Latest Word on the Use of Independent Contractors: Tax, ERISA, and Labor & Employment Law Issues," American Gas Association Thirty-Third Annual Legal Forum, July 2010; and Fulbright & Jaworski L.L.P. Forum, May 2010
• "Dealing with Your Own Expert: Retaining, Working and Tidying Up," ABA-IPT Advanced Property Tax Seminar, March 2010
• "Settling a Tax Case with the Government," Tulane Tax Institute, October 2009

1978 - J.D., Duke University
1973 - B.B.A., University of Florida

Mr. Taylor was admitted to practice law in Texas in 1978. He is also a member of the District of Columbia Bar.

Mr. Taylor has actively litigated in Texas district courts, federal district courts, the U.S. Tax Court, the U.S. Court of Federal Claims and predecessors, and respective appeals courts. He has also represented the Texas State Bar for several years as one of several practitioners attending an annual meeting with IRS regional officials. His professional background includes Big 8 accounting firm experience prior to attending law school.