Samuel A. Lambert

Mr. Lambert is a tax attorney who helps clients resolve problems with the Internal Revenue Service, the Utah Tax Commission, local County Boards of Equalization, and other administrative agencies. Mr. Lambert also advises nonprofit organizations, businesses, and individuals that need guidance regarding complex federal and state tax issues.

Tax Controversy
Mr. Lambert represents clients in all stages of tax controversy – including audits and appeals with the Internal Revenue Service and Utah State Tax Commission, and tax litigation before the Utah State Tax Commission, U.S. Tax Court, and state and federal district courts. He works with CPAs to advance cases that benefit from the expertise of both attorneys and CPAs. He handles controversies involving a wide variety of subject matters, including (but not limited to):

• Income tax
• Employment tax (including trust-fund recovery penalties)
• Penalty abatement
• Worker classification
• Property tax (exemption, valuation, and equalization)
• Sales tax
• Private Foundation Penalty and Excise Taxes
• UBIT
• Federal & State tax exemptions, 501(c) status applications, changes, & revocation defense
• Installment agreements
• Offers in compromise
• Requests for non-collection status
• Lien & Levy defense
• Return preparer penalties
• Petition to Quash an IRS Subpoena
• FBAR filing and offshore account voluntary compliance
• Filing returns after years of noncompliance
• Utah Residency and Domicile

Tax Advice
Many clients seek advice before becoming embroiled in a controversy with the IRS. Mr. Lambert counsels nonprofit and exempt organizations, businesses and individuals who have formation, compliance, and planning questions.

Experience
Mr. Lambert has taught as an adjunct professor at the J. Reuben Clark Law School at Brigham Young University, where he taught a course on taxation of corporations and partnerships, and at the S.J. Quinney College of Law at the University of Utah, where he taught a course on federal income taxation.

Prior to joining the firm, Mr. Lambert served in the U.S. Department of Justice as Counsel to the Deputy Assistant Attorney General in the Tax Division, who oversees all tax settlements and appellate tax litigation in the Department of Justice. Also, as a member of the Appellate Section of the Tax Division, Mr. Lambert successfully handled and argued cases in federal appellate courts across the country. Immediately following law school, Mr. Lambert was a law clerk to Judge Amalya Kearse on the U.S. Court of Appeals for the Second Circuit, in New York City.

Sam is also a 5-time U.S. national board & card game champion.