Jonathan E. Strouse is a partner in the Chicago office of Holland & Knight where he concentrates his practice in the areas of litigation, federal tax litigation and federal tax controversies, including audits and appeals. Mr. Strouse is co-chair of Holland & Knight's Tax Controversy and Tax Litigation Team.
Mr. Strouse has represented numerous taxpayers that cut across diverse boundaries including, but not limited to, federally recognized indian tribes, municipal governments, hedge funds, high-net-worth individuals, trustees of qualified ERISA plans including leveraged and non-leveraged ESOPs, accountants, executors, trustees of various trusts, not-for-profit entities, TEFRA partnerships, individuals involved in Derivium transactions, members and limited liability companies, and S and C corporations (publicly traded corporations as well as privately held). Mr. Strouse has represented large and small taxpayers before the Internal Revenue Service on a wide variety of collection, examination and appeals matters including, but not limited to, listed transactions and other tax avoidance matters, foreign tax issues, "wealth squad" examinations, the trading safe harbor pursuant to Section 864(b), information reporting issues, penalty matters pursuant to Sections 6662 and 6707A, mediation proceedings pursuant to Rev. Proc. 2009-44, transfer tax issues, and various other corporate, partnership, individual, employment and excise tax matters.
Mr. Strouse has a long history of representing taxpayers before the Internal Revenue Service, as well as aggressively litigating tax cases against the federal government in the United States District Court and United States Tax Court. Mr. Strouse has diverse experience in litigating federal tax issues including lien, levy and other collection matters, valuation issues, independent contractor/employee issues, built-in gain issues on conversions of C corporations to S corporations, estate and gift tax issues, tax shelter cases, ESOP issues, excise and payroll tax issues, criminal tax issues including voluntary disclosures, and a wide variety of other complex federal tax matters.
Mr. Strouse has acted as lead trial counsel in the United States Tax Court over the past several years on the following cases:
- Engage Networks, Inc. v. Commissioner: Docket No. 026416-11L (Trial not yet scheduled)
- William Doucas v. Commissioner: Docket No. 012254-10L (Settled prior to trial)
- William and Elizabeth Doucas v. Commissioner: Docket No. 012253-10L (Settled prior to trial)
- Elizabeth Doucas v. Commissioner: Docket No. 012252-10L (Settled prior to trial)
- Greg and Zena Smith v. Commissioner: Docket No. 20552-09L (Settled prior to trial)
- Elizabeth Doucas v. Commissioner: Docket No. 7993-09L (Trial not yet scheduled)
- William Doucas v. Commissioner: Docket No. 7994-09L (Trial not yet scheduled)
- Robert Perry v. Commissioner: Docket No. 22324-08L (Settled prior to trial)
- Terri E. Fuhr v. Commissioner: Docket No. 8815-08 (Settled prior to trial)
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Estate of Allan Shapiro, Deceased, Linda Shapiro, Executor v. Commissioner: Docket No. 7925-08 (Settled prior to trial)
- Robert C. Pfahl, Jr. & Nancy L. Pfahl v. Commissioner: Docket No. 1743-07L (Settled prior to trial)
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William A. & Diane Y. Morris v. Commissioner: Docket No. 051408-06 (Settled prior to trial)
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Open Pantry Food Marts of Wisconsin, Inc. v. Commissioner: Docket No. 20217-06 (Settled prior to trial)
- Estate of William Berenson, Deceased, Frieda Berenson, Executor v. Commissioner: Docket No. 20764-05 (Settled prior to trial)
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Estate of Grace S. Jennings, Deceased, Hugh L. Myers, Executor: v. Commissioner: Docket No. 018411-05 (Settled prior to trial)
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Terri Eleen Fuhr v. Commissioner: Docket No. 15822-05 (Settled post-trial)
- John H. Perkins, Deceased, John H. Perkins, Jr. and Robert G. Perkins, Successors-in-Interest, et al. v. Commissioner: Docket No. 13153-05 (Settled prior to trial)
- Estate of Doris F. Kahn, Deceased et al. v. Commissioner: Docket No. 12551-04 (Decided on summary judgment)
- Carol C. Duncan v. Commissioner: Docket No. 13515-03 (Settled prior to trial)
- J. Betram Moher v. Commissioner: 03474-99 (Settled prior to trial)
Mr. Strouse has also represented taxpayers in the United States District Court and the United States Court of Federal Claims over the past several years relating to the following federal tax refund cases:
- Avri and Marla Horowitz v. United States of America, Southern District of New York, Docket No. 10-Civ-7978 (2010) (Settled prior to trial)
- Jay Horowitz and Carolyn Stankovich v. United States of America, Eastern District of New York, Docket No. 2:10-CV-04845 (2010) (Settled prior to trial)
- Estate of John Liftin v. United States of America, United States Court of Federal Claims, Docket No. 1: 10-CV (2010) (Published at 2011 WL 5395546 (Fed.Cl.)) (Trial not yet scheduled)
- United States of America v. William P. Doucas, et al., Middle District of Florida, Tampa Division, Docket No. 8:10-CV-1998 (2010), (Settled prior to trial)
- Vista Motors Inc., LLC v. United States of America, Northern District of Illinois, Eastern Division, Docket No. 1: 10-CV-0134 (2010) (Settled prior to trial)
- Blue Lake Rancheria and Blue Lake Rancheria Economic Development Corporation v. United States of America: Northern District of California, San Francisco Division, Docket No. C-08-4206 (2008) (Summary Judgment entered for taxpayers by the Court of Appeals for the Ninth Circuit and published at 653 F.3d 1112 (2011))
- William P. Doucas and Elizabeth Doucas v. United States of America, Eastern District of Wisconsin, Docket No. 2:05 CV 1282 (2005) (Post-trial proceeding)
- Supreme Industrial Maintenance Corporation v. United States of America: Northern District of Illinois, Eastern Division, Docket No. 96-CV-2950 (1996) (Settled prior to trial)
Prior to entering law school, Mr. Strouse practiced as a certified public accountant for five years. Mr. Strouse regularly advises other attorneys and certified public accountants regarding their representation of taxpayers before the Internal Revenue Service.