Experience You Can Count On
Rather than employing a combative, confrontational approach that can waste time and money, our attorneys apply a firm but cooperative approach based on legal expertise and extensive knowledge of internal IRS operations, procedures and organizational culture.
Mopsick Carrere, LLP focuses on effective resolution of federal and California state tax controversy issues, including civil fraud and criminal investigations, complex audits and general compliance problems. A particular firm focus is resolving offshore compliance issues for clients with undisclosed foreign assets while avoiding onerous penalties and criminal prosecution.
The ability of the IRS to secure previously secret account information from foreign banks and governments is rapidly expanding through new strict reporting and compliance measures under the Bank Secrecy Act and Foreign Account Compliance Act. The IRS is only now beginning to enforce these new laws which will spearhead the next round of IRS enforcement in 2012 and beyond. Many well-meaning taxpayers, unaware of these new developments, have been caught by surprise. Our attorneys possess the necessary experience to obtain equitable-often favorable-outcomes for these individuals.
Our approach to dealing with the IRS is based on solid experience and common sense. In the great majority of cases, an IRS agent wants to determine the accuracy of the tax reported on a return and move on to the next case as soon as possible. Our experience teaches us that we can be far more effective in representing clients before the IRS by being cooperative and business-like. With years of valuable experience, Mopsick Carrere, LLP takes a logical, effective and sophisticated approach to resolving federal and California state tax issues.
Contact us today if you need legal assistance with any of the following:
- IRS Collection Matters
- Tax Litigation
- Audits, Protests & Appeals
- Tax Shelter & Promoter Defense
- Voluntary Disclosures
- International Tax: Offshore Compliance
- Employment Tax Matter
- Private Letter Rulings
- California State Tax Matters
- Estate Planning
- Business Law
Call 916-963-9980 today to arrange your initial consultation.
Attorney Steven Mopsick
Steve’s 30 years of IRS experience nationally and in the field makes him particularly well-qualified to represent clients with a wide variety of federal tax controversy issues, many of which he has resolved favorably after clients have struggled with the IRS for many years.
With 17 years in private federal tax law practice, Steve has helped clients resolve complex audits, protracted collection proceedings, criminal investigations, and settlement of potentially costly litigation before the U.S. Tax Court. Steve brings effective resolution to the table, with his knowledge of federal tax law and his “inside experience” with the IRS corporate culture and the inner workings of the IRS as a world-wide organization of 100,000 people.
Steve’s career at the IRS began in 1970 as a tax law specialist with the IRS Office of the Chief Counsel in Washington D.C., where he focused on domestic and international corporate acquisitions and mergers. He then served as an IRS trial attorney before the U.S. Tax Court before he became a special assistant to the IRS Deputy Chief Counsel where he helped administer a nationwide office employing 5,000 IRS Counsel and Appeals personnel. In his last Washington position, he maintained close working relationships with the IRS Commissioner’s inner staff, officials and staff at the Treasury Department, the Tax Division of the U.S. Department of Justice, and the Tax Committees of Congress.
Steve’s Washington, D.C. experience allowed him to take part in key policy, legislative and tax administration matters, while at the same time participating in the review and direction of tax law enforcement and litigation policy for the IRS across the country.
In his 15 years as District Counsel for the IRS Sacramento District, he served as chief legal counsel for all IRS posts of duty in Northern California’s thirty-one counties from the Bay Area throughout the entire northern State.
Steve’s long experience with the IRS and his years of private practice have translated into an ability to obtain favorable outcomes for a wide variety of clients in a number of different areas including voluntary disclosures and offshore compliance, tax evasion, “eggshell audits”, offers in compromise, civil fraud investigations, multiple periods of failure to file, as well as IRS liens and levies.
In the area of offshore compliance, Steve has established himself as an experienced authority. He has published several articles about the IRS’s increasing access to undisclosed taxpayer accounts in tax haven countries. He has assisted over fifty families in obtaining Voluntary Disclosures under the IRS’s 2009 and 2011 OVDI Programs. In 2012, Steve was invited to become a member of the American Citizens Abroad’s Professional Tax Advisory Council (PTAC). American Citizens Abroad (ACA) is the voice of Americans overseas. ACA is all-volunteer organizations who represent Americans living outside the U.S. to the Executive Branch of the U.S. Government, U.S. Congress, and the U.S. Federal Judiciary.
He was also an adjunct professor of law teaching IRS civil and criminal practice and procedure at the University of The Pacific, McGeorge School of Law for ten years.
Steve is a graduate of Rutgers College and earned his law degree from Boston College Law School, becoming a member of the Massachusetts Bar in 1970, and the District of Columbia bar in 1972. He later got his Masters of Law in Taxation at Georgetown University.
As Steve is not licensed to practice law in California, his practice focuses exclusively on federal tax practice before the IRS and the U.S. Tax Court and does not include California state tax matters. Although Steve is not a member of the California State Bar Association he has been associated with the Taxation Section of the California State Bar since 1986, when he was the IRS Advisor to the Executive Committee where he served until 1994. Shortly after his departure from the IRS Office of Chief Counsel in 2002, Steve became a public (non-California attorney) member of the Taxation Section Executive Committee where he coordinated events and contacts between IRS officials in Washington, D.C., United States Tax Court officials and judges, and members of the California State Bar Tax Section leadership, between 2005 and 2008. In addition, Steve was involved in establishing the Taxation Section of the Sacramento County Bar Association.
Attorney Ryan Carrere
Ryan’s practice focuses on tax controversy matters before the IRS, California Franchise Tax Board, Employment Development Department, State Board of Equalization, and California Department of Tax and Fee Administration. Ryan also assists clients with business and estate planning matters.
Ryan has extensive experience having practiced for more than 13 years representing and advising clients in a wide range of industries including agriculture, transportation, manufacturing, retail, construction, hospitality, insurance, real estate, medical, and legal. He routinely represents clients in varied and complex tax controversy matters including:
- Tax collection representation before the IRS and all California tax authorities;
- Audit representation;
- IRS and California tax appeals; and
- U.S. Tax Court litigation.
He has extensive experience negotiating resolutions of federal and California state tax debts. Ryan was selected for inclusion as a “Rising Star” by Northern California Super Lawyers in 2015. No more than 2.5 percent of lawyers in the state are named to the Rising Star list.
Ryan earned an undergraduate degree in criminal justice from Northern Arizona University. Ryan is a Marine Corps veteran having served on active duty as a Supply Admin and Operations Specialist in the USMC from 1997 to 2001. Ryan’s responsibilities included supply accounting, inventory management, and requisitions.
Following his honorable discharge in 2001, he attended the University of the Pacific, McGeorge School of Law, and graduated with a law degree in 2004. Ryan is a member of the California Bar and admitted to practice before the United States Tax Court and Federal District Court for the Eastern District of California.
Ryan writes a Blog on tax controversy matters and has co-authored articles published in national publications, Tax Notes and Accounting Today.