Trial Attorney (Tax Litigation Branch)

The Civil Division, Tax Litigation Branch, is looking for attorneys to join its Trial Section. Our attorneys have a passion for litigation; a deep interest in public service; and the ability to work both collaboratively and independently. Well-qualified candidates may be eligible for a signing bonus of up to $25,000, depending on qualifications, education, and other factors. All recipients of a signing bonus are required to fulfill a service obligation. All academic degrees and coursework must be completed at a college or university that has obtained accreditation or pre-accreditation status from an accrediting body recognized by the U.S. Department of Education. For a list of schools that meet this criteria, see www.ed.gov.

OR

Education completed in foreign colleges or universities may be used to meet the above education requirements if you can show that the foreign education is comparable to that received in an accredited educational institution in the United States. It is your responsibility to timely provide such evidence by submitting proof of creditability of education as evaluated by a credentialing agency with your application materials. More information may be found at https://www.ed.gov/about/initiatives/international-affairs/recognition-of-foreign-qualifications

All documentation must be in English or include an English translation. Tax Litigation Branch trial attorneys serve as front-line litigators for the United States in tax disputes in federal district courts, bankruptcy courts, the Court of Federal Claims, and, on occasion, state courts. These cases arise nationwide, and significant travel is required for depositions, hearings, and trials.

Attorneys are responsible for a diverse caseload, handling matters both independently and as part of a litigation team. In all cases, attorneys take primary responsibility for developing and litigating cases, including taking and defending depositions, drafting and arguing motions, working with fact and expert witnesses, and trying cases.

The Branch handles most litigation outside of the Tax Court involving the Internal Revenue Service. In this role, attorneys work on cases that span all sectors of the American economy and involve litigants ranging from individuals and small businesses to the largest corporations.

Representative matters include:

• Defending the United States in tax refund actions
• Bringing affirmative suits to collect taxes, including cases involving complex commercial transactions and fraudulent transfers of property
• Defending challenges to the constitutional and statutory validity of provisions of the Internal Revenue Code and Treasury Regulations
• Obtaining injunctions against individuals and entities engaged in fraudulent tax shelter schemes or the preparation of fraudulent tax returns
• Representing the United States in bankruptcy, receivership, and probate proceedings
• Enforcing civil penalties, including those related to foreign financial account reporting requirements
• Defending Internal Revenue Service employees in Bivens actions
• Enforcing Internal Revenue Service administrative summonses
• Protecting the United States' immunity from state and local taxation

Through this work, attorneys play a critical role in developing federal tax law and ensuring that all taxpayers meet their obligations under the law. Attorneys in this position must be able to work independently to develop their cases factually and legally, and work collaboratively with the Internal Revenue Service, internal supervisors, and peers to present cases in the most effective manner. Excellent written and oral communication skills are essential.

Interested applicants must possess a J.D., or equivalent, degree, be duly licensed and authorized to practice as an attorney under the laws of any State, territory of the United States, or the District of Columbia, and be an active member of the bar in good standing.

• To qualify at the GS-11 grade level, applicants must have up to one (1) year of legal experience.
• To qualify at the GS-12 grade level, applicants must have minimum (1) or more years post-J.D. legal experience
• To qualify at the GS-13 grade level, applicants must possess at least one and one-half (1.5) years of post-J.D. legal experience.
• To qualify at the GS-14 grade level, applicants must possess at least two and one-half (2.5) years of post-J.D. legal experience.
• To qualify at the GS-15 grade level, applicants must possess at least four (4) years of post-J.D. legal experience.

Qualifications must be met by the closing date of the vacancy announcement.

Preferred Qualifications:
In addition to the required qualifications listed above, the ideal candidate will have experience interpreting or applying provisions of the United States Internal Revenue Code, the United States Bankruptcy Code, the Federal Rules of Civil Procedure and/or the Federal Rules of Bankruptcy Procedure, and related laws, rules, and regulations that arise in tax and bankruptcy cases, or other complex legal statutes, rules, and regulations.

Additional desirable experience includes a demonstrated record of analyzing complex legal problems, developing litigation strategies, and superior trial practice skills; working with expert witnesses; managing or working as a member of a trial team; making oral arguments; and trial or evidentiary hearing experience.

The ideal candidate will also have the ability to identify, distill, and explain complex issues, as well as experience working with document management software to review discovery productions (e.g., Relativity or Everlaw) and with trial organization and presentation software (e.g., CaseMap or OnCue). Experience working with or for federal agencies is also preferred.

Trial Period Statement
As a condition of employment for accepting this position in accordance with section 11.5 of Executive Order 14284, you will be required to serve a 2-year trial period during which we will evaluate your fitness and whether your continued employment advances the public interest. In determining if your employment advances the public interest, we may consider:

• your performance and conduct;
• the needs and interests of the agency;
• whether your continued employment would advance organizational goals of the agency or the Government; and
• whether your continued employment would advance the efficiency of the Federal service.

Upon completion of your trial period your employment will be terminated unless you receive certification, in writing, that your continued employment advances the public interest.