Anton Janik is a member of the Litigation Practice Group focusing on complex litigation, cyber security and privacy, and tax controversies. He leads the Tax Controversy and Litigation practice area and co-leads the Cybersecurity, Privacy and Data Protection practice area. Mr. Janik also has experience in the areas of investigations and corporate compliance, employee privacy, data protection and social media. He is a former trial attorney with the U.S. Department of Justice in Washington, D.C., and a Certified Information Privacy Professional/United States (CIPP/US).
- Represents business entities and high net worth individuals before state and federal tax authorities in civil and criminal matters concerning domestic and international tax issues.
- Provides advice and counsel at whatever stage tax issues arise—including the planning and development stage, during the administrative process at federal and state examinations and appeals, and through litigation in state courts, the U.S. Tax Court, U.S. District Courts, the Court of Federal Claims, the U.S. Courts of Appeal and the U.S. Supreme Court
- Advises clients on cybersecurity issues including breach preparedness and breach response.
- Participated in the U.S. Department of Homeland Security’s 2016 Cybersecurity Tabletop Exercise held at the Clinton School.
- Represents business entities and individuals in internal and external investigations and related litigation.
- Appointed as a Trial Attorney in the Tax Division of the U.S. Department of Justice in Washington, D.C., and investigated and prosecuted numerous tax matters throughout the Ninth and Tenth Circuits including tax shelter transactions falling under Notice 2000-44 / Son of BOSS and Notice 2003-55 / Offshore Lease Strip Transactions.
Tax Shelter Investigations:
Central Valley Ag Enterprises v. United States, 326 B.R. 807 (E.D.Cal. 2005) (IRS Notice 2003-55/Offshore Lease Strip Transactions)
In the Matter of Tax Liabilities of John Does (In re Paypal, Inc.), 05-cv-4167 JW (N.D.Cal. 2005) (IRS Rev. Proc. 2003-11/Offshore Voluntary Compliance Initiative)
Sala v. United States, 99 A.F.T.R.2d 2007-1709 (D.Colo. 2007) (IRS Notice 2000-44/Son of B.O.S.S.)
Corporate Investigations & Litigation:
State of Arkansas v. Arrowhead Investments, et al., Case No. 60CV-10-4678 (Pulaski County 2010) (Deceptive Trade Practices/Pay Day Lending)
Associated Electric Cooperative, Inc. and Staple Cotton Cooperative Association v. Town of Dell, et al., Case No. 2012-64 (Mississippi County 2012) (Excessive Privilege Tax Assessments)
Bailey Properties, LLC, Bailey Family Revocable Living Trust, TMP v. Commissioner of Internal Revenue, Case No. 20977-11 (U.S. Tax Court 2011) (Readjustment of Partnership Items)
Colorado Gas Compression, Inc. v. United States, 98 A.F.T.R.2d 2006-7501 (D.Colo. 2006) (IRS Investigative Summons)
Oklahoma Appraisal and Assessment, Inc., et al. v. Arkansas CAMA Technology, Inc., et al., Case No. 2008-9723 (Pulaski County 2008) (Deceptive Trade Practices/Computer Software)
United States ex rel. Rille and Roberts v. Accenture, LLP et al., 04-cv-985 (E.D.Ark. 2004) (Qui Tam – Government Contracts)
United States v. Little John Trucks, Inc., Case No. 11-cv-492 (E.D.Ark. 2011) (Reduce Assessments to Judgment)
United States v. Montgomery Global Advisors V LLC, Case No. 03-cv-733 (N.D.Cal.2006) (IRS Investigative Summonses and Criminal Contempt)
United Systems of Arkansas, Inc. v. Keith Reed, et al., Case No. 60CV-2011-2232 (Pulaski County 2011) (Breach of Contract)
Various Tax Matters:
Abell v. Sothen, 97 A.F.T.R.2d 2006-1804 and 1815 (D.Colo. 2006) (IRS Collections Summons)
Arkansas Teacher Retirement System v. Brenda Short, et al., Case No. 26CV-09-1707 (Pulaski County 2009) (Refund of property taxes erroneously paid)
ARM Financial Corp. v. Daniel Ahlstrom, Case No. 03-cv-1264 (D.Nev. 2005) (Interpleader)
Austin v. Archoice, LLC, Case No. CV 2006-3868 (Pulaski County 2010) (Quiet Title/Tax Seizure)
Cal-Western Reconveyance Corp. v. Residential Property, Case No. 04-cv-564 (S.D.Cal. 2004) (Interpleader)
United States v. Community First National Bank – East, Case No. 03-cv-155 (D.Wyo 2003) (Reduce Assessment to Judgment and Foreclosure)
Devin v. United States, 423 F.Supp.2d 1232 (D.Wyo. 2006) (Enforceability of Tax Compromise Agreement)
Frymark v. United States, Case No. 02-cv-845 (D.Md. 2004) (Responsible Officer/Trust Fund Recovery Penalty)
Green v. United States, 434 F.Supp.2d 1116 (D.Utah 2006) (Foreclosure Redemption)
Hernandez v. State of Wyoming, Case No. 04-cv-134 (D.Wyo. 2004) (Separation of Powers Between State and Federal Governments in Tax Collection)
Holman v. United States, 95 A.F.T.R.2d 2005-1165 (D.Utah 2005) (Nominee Asset Transfer)
In re Pugh, 315 B.R. 889 (B.Nev. 2004) (Responsible Officer/Trust Fund Recovery Penalty)
Johnson v. Commissioner of Internal Revenue, Case No. 25530-10 (U.S. Tax Court, 2010) (Qualified Residence Interest Deduction, Domestic Production Activities Deduction)
Jones v. United States, Case No. 03-cv-762 (D.Colo. 2003) (IRS Collections Summons)
Leach v. United States, 98 A.F.T.R.2d 2006-6199 (D.Mont. 2006) (Tax Exempt Securities)
Lee v. Bass, 345 F.Supp.2d 947 (D.Mont. 2004) (Anti-Injunction Act)
Liniger v. United States, Case No. 05-cv-381 (D.Colo. 2005) (Hobby Losses)
Lister v. United States, Case No. 03-cv-662 (D.Utah 2004) (Collections Due Process)
Murphy v. Marker, et al., 97 A.F.T.R.2d 2006-2209 (D.Utah 2006) (IRS Collections Summons)
Renn v. Wilfley (In re Wilfley), Case No. 06-3231 (B.Or. 2006) (Alleged Tax Fraud)
Rosson v. United States, 127 Fed.Appx. 398 (10th Cir. 2005) (Anti-Injunction Act)
Smith v. United States, 98 A.F.T.R.2d 2006-8093 (D.Utah 2006) (Responsible Officer/Trust Fund Recovery Penalty)
Stanojevich v. United States, Case No. 05-mc-9141 and 05-mc-1299 (D.Or. 2005) (9th Cir. 2006) (IRS Collections Summons)
United States v. Travers, Case No. 03-cv-2112 (E.D.Cal. 2004) (Priority of Tax Liens)
Vision Service Plan v. United States, 96 A.F.T.R.2d 2005-7440 (E.D.Cal. 2005) (Revocation of Tax Exempt Status)