Chad Nardiello is a tax attorney that specializes in civil and criminal tax controversy and litigation matters. He represents clients at all phases of the tax controversy process, including before the Internal Revenue Service (“IRS”) Examination Division (a.k.a. the audit stage) and Appeals Office, during the criminal investigation process, as well as in litigation in the US Tax Court, US Court of Federal Claims, US District Courts, US Bankruptcy Courts and US Courts of Appeal. Mr. Nardiello also represents taxpayers involved in state tax controversy matters, including disputes involving the California Franchise Tax Board, the State Board of Equalization and the Employment Development Department.
Mr. Nardiello previously served as a Trial Attorney with the United States Department of Justice (DOJ), Tax Division, in Washington, D.C., where he represented the United States and the IRS in the litigation of federal tax matters in United States District and Bankruptcy Courts. While working at the DOJ, he was twice honored with a Special Commendation, which is an award given by the United States Assistant Attorney General in recognition of achieving success in litigating a matter of significance to the interests of the United States government. Mr. Nardiello was also selected to serve as a mentor in the United States Attorney General’s Honors Program to incoming attorneys to the Tax Division.
Both before and after leaving the DOJ, Mr. Nardiello worked as a private practitioner specializing in tax controversy and litigation. He has significant private practice experience at the highest levels of the legal industry. Prior to starting the Firm, he practiced in the tax controversy and litigation group of Latham & Watkins, LLP, in Washington, D.C., which is one of the largest, most prestigious international law firms. While at Latham, Mr. Nardiello represented a variety of clients, including large multi-national (Fortune 500 companies) and international clients, and achieved success through trial, briefing without trial, settlements, and in the criminal investigatory process. Mr. Nardiello also practiced at one of the “Big Four” public accounting firms where he focused on tax planning for mergers and acquisitions.
His unique combination of background, experience and expertise allows Mr. Nardiello to attain success on behalf of clients. In the federal courts, he has argued and handled multiple appellate matters and tried numerous cases. Mr. Nardiello has represented corporate and individual clients in criminal cases as both targets/defendants and third-party witnesses, as well as clients undergoing sensitive IRS investigations involving fraud allegations and civil forfeitures. Mr. Nardiello has also successfully represented countless taxpayers during tax audits and in administrative appeals before taxing authorities.
Mr. Nardiello has a deep understanding of substantive tax law, accounting and tax return preparation. He has advised clients on the substantive aspects of transactional tax matters, as well as provide tax controversy advice during the planning stages of a transaction. With a Bachelor of Accountancy and significant experience preparing tax returns for businesses and individuals, Mr. Nardiello has developed the skills necessary to read, understand, and extract information from tax returns in furtherance of his role as a client representative.
Mr. Nardiello has had success in numerous cases, including both public and non-public matters. The following is a list of some of the public cases in which he has had success as either a government attorney or private practitioner that are noteworthy due to the dollar amount and/or the novelty of the legal issue:
Mr. Nardiello has published numerous articles in the area of tax controversy and litigation and been quoted in the national tax press, including on an opinion issued by the United States Supreme Court. The following is a list of those articles and quotes:
Mr. Nardiello regularly speaks on matters related to tax controversy and litigation, including at events before other attorneys, accountants, financial advisers and business executives. He has spoken on panels at events sponsored by the American Bar Association (Taxation Section), California Bar Association, University Southern California, University California Los Angeles, University of San Diego, California Society of CPAS. In addition Mr. Nardiello has spoken outside the United States on matters relating to the IRS International Tax Enforcement.