Christopher S. Rizek
Partner
Overview
Christopher S. Rizek is a tax attorney in Holland & Knight's Washington, D.C., office. Mr. Rizek represents taxpayers in all types of federal civil and criminal tax controversy matters. He guides clients through IRS audits, prepares administrative claims and protests of IRS actions, and litigates tax and tax-related cases in U.S. district and appellate courts, the U.S. Court of Federal Claims and U.S. Tax Court.
In recent years, Mr. Rizek has represented numerous taxpayers, financial entities and professional firms in connection with IRS examinations of tax shelters and related compliance and professional ethics issues.
From 1984 to 1988, Mr. Rizek served as a trial attorney with the U.S. Department of Justice's Tax Division, and he received the Outstanding Attorney Award in 1986. From 1995 to 1998, Mr. Rizek was an attorney-advisor and then associate tax legislative counsel with the U.S. Department of the Treasury's Office of Tax Legislative Counsel, with substantial responsibilities for legislation and regulatory actions involving taxpayer rights, tax practice and procedure, and tax compliance.
Mr. Rizek's combination of practical and policy-level experience in government has given him special insight into the actual application of the tax laws and procedures to taxpayers. This experience has been of great value to his clients who are faced with complex tax controversies and litigation.
Mr. Rizek previously was an adjunct professor in the LL.M. tax program at Georgetown University Law Center and taught a Tax Practice & Procedure (Administrative) course to IRS personnel. He also has been a guest lecturer at other law schools and universities, and is a frequent speaker at conferences on tax procedure and ethics issues.
Prior to joining Holland & Knight, Mr. Rizek was a tax attorney for a national law firm in its Washington, D.C., office.
Representative Experience
- Negotiated a deferred prosecution agreement for a European bank that had participated in the promotion and sale of dozens of "Son of Boss" tax shelters in the United States
- Represented the taxpayers in one of the only litigated cases in which the IRS conceded the deductions taken for insurance premiums paid to a Section 831(b) captive insurer
- Obtained a U.S. Tax Court decision in an estate tax case confirming the marital deduction for conveyances to the decedent's wife, after the IRS contested the validity of a religious divorce the decedent had obtained from his first wife
- Obtained a summary judgment on the issue of whether a taxpayer's disclosure on a delinquent gift tax return was sufficient to commence the applicable statute of limitations, which barred the IRS's deficiency proceeding
- Negotiated settlements of IRS penalties and disciplinary sanctions for numerous law and accounting firms as well as individual practitioners related to their promotion, sale and advice regarding abusive tax shelter transactions
- Obtained the complete dismissal of a complaint to the IRS Office of Professional Responsibility regarding alleged improper behavior by a tax collection resolution firm
- Argued and won a U.S. District Court case contesting the authority of the IRS to regulate contingent fees charged in connection with refund claims
- Advised numerous law firms, accounting firms and tax return preparers regarding their compliance obligations under the Internal Revenue Code and related professional regulations
Credentials
- Georgetown University Law Center, LL.M.
- Georgetown University Law Center, J.D.
- Dartmouth College, A.B.
- District of Columbia
- Maryland
- U.S. Tax Court
- U.S. Court of Appeals for the Fourth Circuit
- U.S. Court of Appeals for the Eleventh Circuit
- U.S. Court of Appeals for the District of Columbia Circuit
- U.S. Court of Appeals for the Federal Circuit
- U.S. Court of Federal Claims
- U.S. District Court for the District of Columbia
- U.S. District Court for the District of Maryland
- U.S. District Court for the Eastern District of Michigan
- American Bar Association, Section of Taxation and Litigation Section
- American Bar Foundation, Fellow
- American College of Tax Counsel, Fellow
- District of Columbia Bar, Taxation Section
- Federal Bar Association, Section of Taxation
- Anne Arundel (Maryland) County Ethics Commission, 2003-2008
- Law & Policy in International Business, Editor, Georgetown University Law Center, 1981-1982
- The Legal 500 USA, Tax – U.S. Taxes: Contentious, 2011, 2014-2015, 2017-2019, 2021-Present; Leading Lawyer, 2013-2017
- Chambers USA – America's Leading Lawyers for Business guide, Tax, 2012-Present
- The Best Lawyers in America, Tax Law, and Litigation and Controversy – Tax, 2005-Present
- Washington, D.C., Super Lawyers magazine, Tax: Disputes and Litigation, 2008-Present
- The Washingtonian, Lifetime Achievement Lawyer, 2022; Top Lawyers, 2015-Present
- Who's Who Legal, Corporate Tax, 2018-Present
- Martindale-Hubbell AV Preeminent Peer Review Rated