Janice Feldman

After retiring from government service in 2019, Ms. Feldman spent two years as a volunteer attorney for the Harvard University School of Law Federal Tax Clinic. She is admitted to practice law in the District of Columbia, Maryland, and US Tax Court, having earned her Juris Doctor from Boston University School of Law in 1988, and her Bachelor’s degree, magna cum laude, from Brandeis University in 1985.

Janice has worked as a tax attorney for over 35 years, both in private practice and in government. She has had exposure to numerous tax issues in a variety of settings. Below is a list of some of her experiences.

• Lead counsel in over 2,000 cases as a trial attorney at the Department of Justice, Tax Division, Civil Trial Section, Southern Region.
• Represented the United States in trust fund recovery penalty cases in both the District Court and Bankruptcy Court.
• Represented the United States in wrongful levy actions, suits to reduce assessments to judgment, fraudulent conveyance cases, and quiet title actions.
• Recognized expert on innocent spouse issues at the IRS Office of Chief Counsel. Authored Chief Counsel Notice on frequently asked questions on innocent spouse cases, coordinated litigation strategy with regard to jurisdictional issues, and taught training seminars on the topic to both attorneys and IRS personnel and at the ABA.
• Handled a variety of cases at Harvard Law School Tax Clinic, involving numerous issues including innocent spouse, collection, examination, and identity theft.
• Assisted drafting the amicus brief filed in the United States Court of Appeals for the 9th Circuit by the Harvard Tax Law Clinic in Seaview Trading, LLC v. Commissioner. The case dealt with issues regarding the time limit for assessing tax.
• Assisted drafting the amicus brief filed in the United States Court of Appeals for the 9th Circuit by the Harvard Tax Law Clinic in Jones v. Commissioner. The case concerned the issue of whether the taxpayer had filed a joint return.
• Presenter of the program “Innocent Spouse 101: Relief from Joint Income Tax Liability” at the Bar Association of Montgomery County virtual CLE meeting, May 2023.
• Moderator on a virtual panel discussing the Impact of Late-Issued Collection Notices in Bankruptcy and Tax-Related District Court Litigation at a virtual ABA meeting in January 2022.
• Speaker on Innocent Spouse panel at the ABA 35th National Institute on Criminal Tax Fraud and Eighth Annual National Institute on Tax Controversy, December 2018.
• Leader of the Collection Due Process (CDP) working group, a cross-functional team made of various IRS and IRS Counsel personnel that sought to make CDP program enhancements and correct program issues.
• Primary drafter of the Taxpayer Assistance Order regulations, 26 CFR § 301.7811-1.
• Taught classes to both IRS and IRS Counsel on many issues, including collection, nominee liens, foreclosure, CDP, innocent spouse, Offers in Compromise (OIC), handling cases, Appeals, and taxpayer assistance orders.