Jenny L. Johnson

Partner
  • T 312.578.6523

Jenny Louise Johnson, a partner in Holland & Knight's Chicago office, leads the Tax Controversy and Litigation Team.

Ms. Johnson has substantial experience handling criminal and civil tax disputes and has clients ranging from individuals to multinational corporations. She represents clients through all stages of criminal and civil tax investigations and litigation, including voluntary disclosures, sensitive audits and examinations, search warrants, grand jury subpoenas, negotiated resolutions with the IRS and the Department of Justice, trials in federal district court and the United States Tax Court, sentencings and appeals. Ms. Johnson handles disputes involving income taxes, estate and gift taxes, excise taxes, employee plan matters and tax exempt bonds.

Ms. Johnson is an adjunct professor on the tax faculty at Northwestern University School of Law, currently teaching criminal tax. She is also a frequent speaker and faculty member at conferences across the country, and is in the upper echelon of nationally recognized tax litigators.

Ms. Johnson represents clients who have been targeted for criminal prosecution as a result of their unreported foreign bank accounts, and has successfully handled numerous voluntary disclosures to the IRS regarding offshore bank accounts. As a result of her familiarity with the nuances of the reporting requirements, Ms. Johnson routinely advises individual, corporate and fiduciary clients with respect to their reporting obligations under the Internal Revenue Code, the Bank Secrecy Act and the Foreign Account Tax Compliance Act (FATCA).

Combining her well-honed trial skills with a sophisticated understanding of the underlying tax issues and IRS procedures, Ms. Johnson also successfully represents clients in criminal tax investigations and high-stakes civil tax litigation. Her practice includes cases on the cutting edge of tax litigation, including a robust assortment of TEFRA partnership cases and two of the first cases involving a "Midco" listed transaction to be tried in the Tax Court. Ms. Johnson has several other transferee liability cases pending and regularly receives requests for consultations on this type of case from attorneys across the country.

Ms. Johnson has also attained favorable settlements of many disputes with the IRS, before or during litigation, and routinely provides behind-the-scenes strategic counseling to clients and their other advisors on potential or existing tax-related disputes. For example, Ms. Johnson represented a plan sponsor who faced an IRS threat of disqualification of its qualified plans and achieved a favorable closing agreement after protracted negotiations that involved the highest-ranking Employee Plans officials in the IRS. Ms. Johnson also frequently works with high net worth individuals, families and their other advisors to identify potential audit risks and navigate enterprise examinations pursued by the IRS Global High Wealth Industry Group.

Ms. Johnson launched a new pro bono initiative in Chicago, representing low income taxpayers in front of the U.S. Tax Court. Partnering with the Center for Economic Progress, Ms. Johnson and her team developed a program to train attorneys and law students to represent low income taxpayers, and then appear in court to assist taxpayers who arrive for their required hearing without legal assistance. She also represents children in juvenile delinquency proceedings, immigrants seeking asylum and those who have been wrongly convicted.

Honors & Awards

  • Chicago's Rising Stars: 40 Under 40, The National Law Journal, 2013
  • Rising Star, Illinois Super Lawyers magazine, 2013-2014

Memberships

  • American Bar Association, Section of Taxation, Civil and Criminal Tax Penalties Committee, Legislative and Administrative Developments Subcommittee, Chair
  • American Bar Association, Real Property, Trusts and Estates Law Section, Income and Transfer Tax Planning Group, Tax Litigation and Controversy Committee, Chair
  • American Bar Association, Criminal Justice Section, White Collar Crime Committee
  • Better Government Association, Board of Directors
  • Harvard Law Society of Illinois, Board of Directors
  • Chicago Inn of Court