Lawrence (Larry) Sannicandro is a partner at Kostelanetz & Fink and focuses his practice on federal and state tax controversies, including representation in audits, administrative appeals, collection matters, summons proceedings, criminal tax investigations and prosecutions, and litigation in the United States Tax Court, federal district and appellate courts, and state tax tribunals. Mr. Sannicandro has extensive experience providing tax-related advice with respect to original tax return reporting positions on a broad range of substantive tax issues, amending tax returns, filing and litigating claims for refund, challenging civil tax penalties, reporting foreign assets and income, and making voluntary disclosures.
Mr. Sannicandro serves as the Chair of the Tax Collection, Bankruptcy and Workouts Committee of the American Bar Association (ABA) Section of Taxation. On behalf of the ABA Section of Taxation, he has drafted comments to Congress and the IRS on a wide range of tax issues, such as reforming the procedures for auditing and litigating against partnerships and the need to adopt a voluntary disclosure program for unreported cryptocurrency transactions. For his service to the ABA, Mr. Sannicandro was awarded the John S. Nolan Fellowship.
Mr. Sannicandro also teaches a course in tax practice and procedure as an adjunct professor at Fairleigh Dickinson University, and he has taught classes on corporate tax, partnership tax, and negotiations as an adjunct professor at Pace University and a lecturer at Georgetown University Law Center and Rutgers Law School.
Mr. Sannicandro is a dedicated pro bono advocate. He works with the After Innocence organization to provide tax-related advice to wrongfully convicted individuals. For his work in co-designing and co-implementing an entirely new form of low-income taxpayer assistance, the ABA Section of Taxation awarded Mr. Sannicandro the 2020 Janet Spragens Pro Bono award, the Section of Taxation’s highest award for pro bono. Mr. Sannicandro also regularly appears on behalf of taxpayers as part of the New York County Lawyers Association’s U.S. Tax Court Calendar Call Program. The New York County Lawyers Association awarded Mr. Sannicandro its Pro Bono Award in 2015.
Prior to entering private practice, Mr. Sannicandro served as a law clerk for the United States Tax Court, and before that, as an attorney for the IRS. He earned his LL.M. in Taxation from Georgetown University Law Center, his J.D. from the University of Florida Levin College of Law, and his M.B.A. in Finance from Binghamton University.
Mr. Sannicandro is a frequent author on tax practice and procedure, having published articles in the Journal of Tax Practice and Procedure, Law360, Tax Notes®, TAXES – The Tax Magazine®, The New Jersey Law Journal, and the Westlaw Journal. He is the co-author of Qualified Appraiser, Qualified Appraisal: Practice, Procedure, Legal Analysis, and Theory (John Wiley & Sons, Inc. 2017), and Tax Practitioner’s Guide to Identity Theft (CCH, Inc. 1st ed. 2015; 2d ed. 2016). He is also a contributing author to the Effectively Representing Your Client Before the IRS (Chapter 10 of the ABA Section of Taxation’s guide).
Virtual currencies, including cryptocurrency, have recently received significant attention from the IRS, the Financial Crimes Enforcement Network, the U.S. Department of Justice Tax Division, and other law enforcement agencies. The panelists, led by ...