Tax Advice:
We provide tax advice to individuals and closely-held businesses. We have experience in the following matters:

• Federal and state tax planning in connection with the formation, acquisition, disposition, reorganization, and liquidation of closely-held businesses, partnerships, and joint ventures;
• Practice before the IRS National Office and the Treasury Department in connection with requests for advance rulings, technical advice, and regulatory tax matters;
• Federal and state planning for inbound and outbound transactions involving foreign taxpayers, foreign currency; and other international tax matters;
• Tax dispute resolution by working with all levels of the IRS including examination, collection, appeals, taxpayer advocates and IRS counsel to efficiently resolve tax and penalty liability issues.
  

Our tax advice practice has a broad and diverse client base. We constantly keep up with the frequent changes enacted by Congress, the IRS, and other regulatory agencies which expand or modify the complex legal requirements applicable to tax planning and employee benefits.

Tax Controversy:
We represent clients in civil and criminal tax proceedings before federal, state, local, and foreign tax authorities, and courts involving a broad spectrum of income, estate, gift, excise, franchise, property, license, sales, use, and value added taxes. We have knowledge not only with the tax administration operation of clients but also with the transactions and operations that give rise to tax issues. By doing so, we are able to determine the appropriate level for resolution of actual and potential issues, including agency and judicial relief. Our attorneys have experience in:

• International, federal, state, and local tax advocacy at every administrative and judicial level;
• Federal, and state tax controversies arising out of the formation, acquisition, disposition, reorganization, and liquidation of closely-held corporations, partnerships, and joint ventures;
• Advocacy before the IRS National Office and the Treasury Department in connection with requests for advance rulings and technical advice;
• Federal, and state tax controversies related to inbound and outbound transactions of foreign and domestic taxpayers, foreign currency transactions and other international issues;
• Federal and state tax controversies in connection with corporate reorganizations, partnerships syndication, stock and debt offerings, tax-exempt financings and sophisticated real estate transactions; 
• Defense of promoters of tax shelters and their investors in civil and criminal proceedings.

White Collar Crime Defense:
Increasingly, federal, state, and local governments are relying upon the criminal justice system as a means of regulatory enforcement. We have experience in representing companies and individuals who are the subject of governmental inquiries ranging from administrative proceedings to grand jury investigations to forfeiture proceedings. We work closely with clients to prevent or minimize formal charges by providing counsel and guidance during governmental investigations involving federal government, including Department of Justice and Internal Revenue Service. Regardless of the nature of the issue or the stage to which the investigation or proceeding has progressed, our attorneys have the resources and experience to see you through this complex area of law.

Private Client/Estate Planning:
Personal service and attention to individual, business, and family circumstances are hallmarks of our private client practice. Our attorneys represent clients throughout the United States, ranging from individuals, families, and closely-held businesses to major trust and charitable institutions. Our lawyers engage in complex planning, probate and trust administration, and related legal services for family and individual clients; including:

• Estate planning
• Will and trust preparation
• Closely-held business practice
• Estate, gift, income tax advice
• Will, estate, trust litigation
• Marital agreements
• Business continuation planning
• Generation-skipping tax planning
• Estate and trust administration
• Insurance trusts
• Retirement benefit planning
• Guardianships/conservatorships
• Medicaid/Medicare trust planning
• International estate tax planning
  

Tax Malpractice:
We often represent Plaintiffs in tax malpractice lawsuits against attorneys who breached their contractual obligations and failed to use due care with respect to tax planning and representation. We testify as tax experts with respect to the duties of care and negligence.

Tax Whistleblower Representation:
We represent tax whistleblowers before the IRS Tax Whistleblower Reward Program. We will increase the chances of award by carefully evaluating your claim. In addition to completing Form 211, we will do the following:

• Determine the statute of limitations in the matter for the years about which you have information and what years are realistically at issue;
• Realistically estimate the unpaid tax based upon information you provide, determine the type and amount of penalty likely to be imposed by the IRS, and calculate the interest on the tax and penalty, in an effort to determine if the case meets the minimum threshold; and
• Present the facts and issues in a simplified and easily understood manner, supported by documentation or other detailed information that will give credibility to the submission of information;
  

We will also evaluate the following risks:

• If the tax whistleblower’s involvement in the underpayment of tax by a taxpayer might subject the whistleblower to criminal prosecution;
• If the tax whistleblower obtained information and documentation while employed by or working as an independent contractor for the taxpayer, whether the gathering of such information might subject the whistleblower to damages for violating “fiduciary duties”, breach of contract, theft, etc.; and
• If the tax whistleblower is an accountant or lawyer, whether or not such information is subject to “privilege” or confidentiality such that the whistleblower might lose his/her license.
  

We will increase your award. As former IRS attorneys we will strive to increase the reward under IRC 7623 from 15% to the maximum 30% by presenting your information along with the following documents:

• Create an “Administrative File” similar to what is normally created by the IRS in an examination;
• Prepare an "audit plan" for the IRS to follow; 
• Prepare Information Document Requests (IDRs)/Summonses normally issued by the IRS, in order further to develop the case on behalf of the IRS;
• Prepare the case for litigation before the U.S. Tax Court by identifying witnesses whose testimony may be necessary at trial, obtaining certified documents for the benefit of the IRS in proving its case, and providing the IRS with other relevant documents as though the case were going to be litigated by your whistleblower attorney; and
• Prepare a legal tax opinion providing the facts and legal analysis. If you decide to hire an attorney, you should get an attorney who can best maximize your reward and minimize your exposure.
  

If you or someone you know needs the assistance of an experienced St. Louis Tax Litigation Attorney, call Robert J. Stientjes of Stientjes & Tolu LLC today at 866-781-6112, or complete the contact form provided on this site to schedule a free consultation. Our firm also provides legal services related to all matters of Immigration Law.

If you or someone you know needs the assistance of an experienced St. Louis Tax Litigation Attorney, call Robert J. Stientjes of Stientjes & Tolu LLC today at 866-781-6112, or complete the contact form provided on this site to schedule a free consultation.  Our firm also provides legal services related to all matters of Immigration Law.

ADDRESS OF THE FIRM:
Stientjes & Tolu LLC
9378 Olive Blvd Suite. 325
Saint Louis, MO 63132
Phone: 866-781-6112
Hours: M-F, 8:00AM-5:00PM

MEMBERS OF THE FIRM:

• Attorney Robert J. Stientjes

Rob defends clients in criminal and civil tax proceedings as well as provides tax planning advice to numerous business clients. He has litigated and negotiated settlements for clients involved in “Listed Transactions” deemed by the IRS to be abusive tax-shelter arrangements. He often represents clients before the IRS criminal and civil examination divisions, appeals division, the U.S. Tax Court, the Court of Federal Claims, and various U.S. District Courts. Rob counsels clients before the IRS with respect to non-cash charitable contributions, deferred compensation, offshore trusts and corporations, discharge of indebtedness income, and federal excise tax. In addition, Rob serves as a tax expert in criminal and civil tax proceedings and represents plaintiffs in tax and accounting malpractice cases.

Rob also routinely advises foreign nationals on Internal Revenue Service international compliance matters such as reporting of foreign bank accounts and financial accounts, reporting and withholding taxes on U.S. source income generated by foreign nationals as well as tax return reporting and compliance for foreign nationals.

He counsels and assists foreign nationals with most common tax return errors such as improper deductions, incorrect personal exemptions, improper tax treaty benefit claims, inaccurate filing status, errors with temporary-away-from home deductions, taxable capital gains on stock sales and disclosure compliance documents for resident aliens who are maintaining income producing assets overseas or are transferors of assets to foreign entities, are grantors of, or recipients of, income from foreign trusts. He also advises clients on tax implications of certain tax gifts or bequests from abroad. Rob also represents foreign nationals who failed to file federal and state tax returns before IRS and state taxing authorities.

Rob defends immigrants facing visa and passport fraud, money laundering, and tax fraud charges. Prior to entering private practice, Rob was a Senior Attorney in the Office of Chief Counsel to the IRS and the Attorney Advisor to the Chief Judge of the U.S. Tax Court. Rob is an adjunct Professor at the St. Louis University School of Business and Accounting where he teaches courses in Tax Administrative Procedure and Tax Litigation Procedure.

Rob is also a professor at the St. Louis University School of Business, Department of Accounting where he teaches courses in Tax Administrative Procedure and Tax Litigation Procedure. Prior to entering private practice, Rob was the Attorney-Advisor to the Chief Judge of the U.S. Tax Court and Senior Attorney in the Office of Chief Counsel to the IRS.

Education:

• Georgetown School of Law, LLM in Taxation with distinction, 2001
• University of Missouri, J.D., Certificate in Tax, 1999
• University of Missouri, B.A., 1995

Bar Admissions:

• Missouri
• United States District Courts in Missouri
• United States Tax Court
• United States Court of Federal Claims

Speeches/Lectures:

• Speaker, Federal Taxation Seminar, University of Missouri School of Law, May 2005
• Speaker, Settlement Strategies for Federal Tax Controversies, Bar Association of Missouri-St. Louis, April 2003