Chuck Hodges focuses his practice on federal tax controversies and litigation and assists U.S. taxpayers facing tax disputes around the world. He has been involved in more than 125 cases against the IRS in the U.S. Tax Court; U.S. Court of Federal Claims; U.S. District Courts in Georgia, South Carolina, Florida, Texas, Delaware, Mississippi, and Arizona; and Courts of Appeals for the Fifth, Sixth, Ninth, and Eleventh Circuits. Among his reported cases are Caracci v. Commissioner, 456 F.3d 444 (5th Cir. 2006) (intermediate sanctions/excise taxes) and Wright v. Commissioner, 809 F.3d 877 (6th Cir. 2016) (foreign currency contracts). By combining his tax law background with his master's degree in economics, Chuck also advises clients on transfer pricing issues and the global taxation of intellectual property.
For more than 20 years, Chuck has handled every stage of a tax controversy from examination (including the CAP program) through court proceedings and all alternative dispute resolution options, including post-IRS Appeals mediation. He represents Fortune 500 companies and their executives, privately held businesses, estates, high net worth individuals and their family offices, as well as exempt organizations.
Chuck is an international tax columnist for the Journal of Taxation and serves as chair of the Federal Bar Tax Section for Atlanta, secretary/treasurer of the Atlanta Bar Tax Section, and is a former chair of the Georgia Bar Tax Section. He is also a Fellow of the American College of Tax Counsel and a Fellow of the American College of Trusts & Estates Counsel (for tax controversies and litigation).
With the current filing of the first returns under the Tax Cuts & Jobs Act of 2017 (TCJA), taxpayers can expect increased IRS scrutiny in the future and the submission of more cases to the IRS Appeals Office. This presentation, by three tax litig...