Education

University of Wisconsin Law School, J.D., cum laude
University of Wisconsin, B.B.A., with distinction, Finance and Accounting

Bar Admissions

Wisconsin
Illinois

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Jonathan E. Strouse

Partner
Chicago
t: 312-715-5741

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 chair of Holland & Knight's Tax Controversy and Tax Litigation Team.

Mr. Strouse has a long history of representing taxpayers before the Internal Revenue Service as well as 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 a wide variety of federal tax issues including 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, excise and payroll tax issues, and a wide variety of other complex tax matters.

Further, Mr. Strouse has represented numerous taxpayers that cut across diverse boundaries including, but not limited to, Indian tribes, municipal governments, trustees of qualified ERISA plans including leveraged and non-leveraged ESOPs, accountants, executors, trustees of various trusts, not-for-profit entities, partners and 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 filed numerous appearances as lead trial counsel in the United States Tax Court over the past several years including:

  • Terri E. Fuhr v. Commissioner: Docket No. 8815-08 (Trial not yet scheduled)
  • Estate of Allan Shapiro, Deceased, Linda Shapiro, Executor v. Commissioner: Docket No. 7925-08 (Trial not yet scheduled)
  • Robert C. Pfahl, Jr. & Nancy L. Pfahl v. Commissioner: Docket No. 1743-07L (Trial postponed; to be rescheduled)

  • William A. & Diane Y. Morris v. Commissioner: Docket No. 051408-06 (Settled prior to trial)
  • 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)
  • Estate of Grace S. Jennings, Deceased, Hugh L. Myers, Executor: v. Commissioner: Docket No. 018411-05 (Settled prior to trial)
  • 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 filed appearances in the United States District Court over the past several years relating to Federal tax refund cases:

  • 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) (Trial not yet scheduled)
  • 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.

Professional Honors & Awards

  • Certified Public Accountant
  • Beta Alpha Psi Honorary Accounting Fraternity

Memberships

  • ABA Tax Section, Member- Court Procedure and Practice Committee
  • Illinois CPA Society, Taxation Practice and Procedures Committee

Court Admissions

  • Trial Bar for the United States District Court for the Northern District of Illinois
  • U.S. Tax Court
  • U.S. Court of Federal Claims
  • All State Courts in Illinois
  • U.S. District Court for the Eastern District of Wisconsin
  • All State Courts in Wisconsin
  • U.S. District Court for the Northern District of Illinois

Speaking Engagements

  • Moderator - Selective Discovery Issues in Civil Tax Litigation, ABA Section of Taxation, July 18, 2008
  • Tax Controversies and Procedure, Members of the Florida Institute of Certified Public Accountants, June 15, 2007
  • Moderator- 5th Amendment Claims in Civil Tax Litigation, ABA Section of Taxation, January 19, 2007
  • Judicial Estoppel in Tax Cases, ABA Section of Taxation, September 16, 2005
  • International Discovery: How to Obtain Discovery for Your Clients Outside the United States, ABA Section of Taxation, September 12, 2003

Published Articles & Books

  • "Where the IRS Is Concerned, No Good Deed Goes Unpunished," Private Wealth Services, Newsletter - Fall 2004
  • "Taxation of Online Commerce," The SPA's Legal Guide to Doing Business On the Internet, 1996
  • "Redemption and Cross Purchase Buy-Sell Agreements: A Comparison," The Practical Accountant, October 1991
  • "Accountants Legal Liability to Third Parties for Negligently Audited Financial Statements," Wisconsin CPA, 1986
  • "Jones v. Commissioner: Employment -Related Awards Under Section 74," The Tax lawyer, 1985