Of Counsel at Morrison Foerster, Edward Froelich represents clients in audit and litigation on all Federal tax issues. Mr. Froelich has litigated a number of tax cases and represented clients in numerous IRS audits and Appeals proceedings. He is a former trial attorney of the Department of Justice Tax Division where he litigated numerous cases, including complex corporate cases. He represented the Government in large corporate refund actions including the closely-watched Lockheed Martin case in which the Government prevailed in the U.S. Court of Federal Claims in a published decision on a $65 million research tax credit issue. In private practice he continues to litigate cases and represents clients in administrative controversies at both the audit and appeals level before the IRS. His Government experience informs his approach to administrative controversies. His litigation experience has been crucial to securing favorable resolutions of matters with the IRS Appeals Office and in the field. His representation is varied and includes large public companies, privately-held companies, partnerships, trusts, and individuals. Many of his clients are in the financial, technology, and real estate industries. He has successfully dealt with a variety of issues including international tax, transfer pricing, income tax accounting, research credit, and listed transaction issues. He also regularly defends clients against a variety of civil tax penalties including delinquency and accuracy-related penalties and regularly advises on privilege and work product questions.
Education:
LL.M., Georgetown University Law Center (1999)
J.D., University of Virginia School of Law (1994)
M.A., Catholic University of America (1991)
B.A., Thomas Aquinas College (1988)
Bloomberg BNA Tax Management Portfolios:
635 T.M., Privilege in Tax and Accounting Matters
5511 T.M., The Section 7525 Tax Practitioner-Taxpayer Privilege and Related Issues (co-author)