Richard Lee Hunn
Norton Rose Fulbright US LLP
Attorney, Internal Revenue Service Office of Chief Counsel, Houston District Counsel Office, Houston, Texas, 1987 - 1997
Special Trial Attorney, Internal Revenue Service Office of Chief Counsel, Midstates Regional Counsel Office, Dallas, Texas, 1997 - 1999
Counsel/Senior Counsel, Norton Rose Fulbright (Fulbright & Jaworski LLP), Houston, Texas, 1999 - present
Richard spent the first twelve years of his career with the Internal Revenue Service Office of Chief Counsel – ten as an Attorney in the Houston District Counsel Office and two as a Special Trial Attorney in the Midstates Regional Counsel Office. He entered private practice in 1999, joining the Firm's Houston office, and has been in private practice for more than 20 years.
Throughout his career, Richard has focused his practice on federal tax controversies. Due to the combination of his government and private practice experience, he has developed a unique understanding of both sides of tax controversies and an extensive knowledge of federal tax procedure.
Richard has handled a wide variety of federal tax cases, including matters pertaining to income tax, estate and gift tax, employment taxes, and excise taxes, involving corporations, partnerships, individuals, and exempt organizations. He has handled examination cases at various stages of the process, from the inception of an examination, through information document requests, summonses, settlement initiatives, administrative appeals, and litigation. He has handled hundreds of cases in United States Tax Court, taking a number of cases to trial, and has handled cases in the U.S. Court of Federal Claims, federal district court and several U.S. Courts of Appeals. He has also handled criminal investigations and collection matters, and has advised clients with potential federal tax compliance issues prior to the development of any controversies.
JD, The University of Texas School of Law, 1987
BBA, with Highest Honors, International Business, The University of Texas at Austin, 1984
While attending law school, Richard was a member of the International Law Society.
Admitted to practice in Texas; admitted to practice before U.S. Tax Court, U.S. Court of Federal Claims, U.S. District Court for the Southern District of Texas, U.S. Courts of Appeals for the Second Circuit, Fifth Circuit, D.C. Circuit, and Federal Circuit.
- Texas State Bar
- Represented individual before U.S. district court and U.S. Court of Appeals regarding enforceability of IRS summons.
- Represented individual and corporation before U.S. Court of Federal Claims and U.S. Court of Appeals regarding tax shelter registration penalties.
- Represented individual before U.S. Tax Court regarding transferee liability issues in connection with corporate and partnership transactions
- Represented public transportation company before U.S. Tax Court regarding worthless stock loss deduction
- Represented chemical transportation and storage company before IRS Examination function and IRS Appeals Office regarding income, expense, withholding and penalty issues in connection with international transactions
- Represented partnership entity before IRS Appeals Office regarding tax treatment of complex financial derivative transaction
- Represented public refining company in connection with IRS summonses regarding international transaction, involving attorney-client, work product and tax practitioner privilege issues
- Represented twenty high net worth individuals, and associated partnership and trust entities, before IRS Examination function and IRS Appeals Office in connection with IRS settlement initiatives involving listed transactions
- Represented public manufacturing company before U.S. Tax Court regarding deductions in connection with corporate restructuring transaction
- Represented partnership before U.S. Tax Court regarding issues in connection with disposition of the assets of a gas-fired power plant, including associated power purchase agreements
- Represented industrial laundry company before U.S. Tax Court regarding expense, depreciation and accounting method issues
- Represented labor union before U.S. Tax Court regarding unrelated business taxable income and statute of limitations issues
- Represented construction company before U.S. Court of Federal Claims regarding employment tax issues involving reimbursement of employee expenses
- Represented IRS before U.S. Tax Court in case involving deductions claimed for dismantlement, removal and restoration expenses with respect to oil and gas facilities at Prudhoe Bay, Alaska
- Represented IRS before U.S. Tax Court in case involving transfer pricing/cost sharing, accounting method, and research credit issues involving computer software
- Special Act Award, Internal Revenue Service, 1991
- Performance Award, Internal Revenue Service, 1992 - 1994, 1997
- Attorney of the Year, Southwest Region, Internal Revenue Service, 1995
- Honorary Special Agent, Assistant Commissioner for Criminal Investigation, Internal Revenue Service, 1995
- Chief Counsel National Team Litigation Award, Internal Revenue Service, 1998
- Co-author, "Who Is Interested in My Request for Interest?" Tax Executive, July 9, 2021
- "Federal Tax Practice Ethics and Circular 230," Texas Tax Lawyer, Practitioner's Corner, Winter 2019
- "Federal Tax Practice Ethics and Circular 230," Texas Tax Lawyer, Practitioner's Corner, Winter 2017
- Co-author, "Transfer Pricing Audits Under the New IRS Roadmap and Disputing Proposed Adjustments," Insights, Winter 2015
- Co-author, "What If My Client's Settlement Agreement With The IRS Has A Mistake?", Texas Tax Lawyer, Fall 2014
- "The IRS: A Former Insider's View of How It Is Organized and How It Works," Texas Tax Lawyer, Practitioner's Corner, Winter 2014
- "Federal Tax Practice Ethics and Circular 230," Texas Tax Lawyer, Practitioner's Corner, Fall 2013
- Co-author, "IRS Targets Employment Taxes To Close Tax Gap," Fulbright Briefing, October 9, 2009, published by Mondaq, November 3, 2009
- "IRS Criminal Tax Symposiums," featured speaker:
- Fort Worth, Texas, December 1992
- Houston, Texas, March 1993
- Charlotte, North Carolina, June 1993
- Presented "The IRS: A Former Insider's View of How It Is Organized and How It Works" to Firm tax associates in 2006, 2010 and 2013.
- Presented "Schortmann v. United States: Overpayment Interest in Settlements with the IRS and Potential Traps for the Unwary" to Firm tax department and a major client, May 29, 2008.
- Presented "Federal Tax Practice Ethics and Circular 230" to Firm tax department, April 30, 2013 and May 24, 2016.
- Presented "Federal Tax Practice Ethics and Circular 230" to Houston CPA Society, Management of an Accounting Practice Committee, May 21, 2013.
- Co-presented (with Robert C. Morris) "Updates from the Trenches on Recent IRS Enforcement Efforts" to Tax Executives Institute IRS Administrative Roundtable, October 2, 2013
- Presented "The IRS: A Former Insider's View of How It Is Organized and How It Works" at State Bar of Texas Tax Section's Tax Law Survey in a Day, Dallas, Texas, February 28, 2014
- Co-presented (with Jasper G. Taylor III) "The Anatomy of a Promoter Penalty Investigation and Why Accounting Firms Should be Wary," October 21, 2014
- Presented "Federal Tax Practice Ethics and Circular 230" to Houston Bar Association Taxation Section, December 15, 2016.
- Co-presented (with Gary Levin) "Experts and Summary Witnesses" at Norton Rose Fulbright and Deloitte Tax Controversy School, New York, New York, March 7, 2017.
- Co-presented (with Chuck Hurley) "Litigation Hold Orders," "Pre-Filing Factual Development," "Experts and Summary Witnesses," and (with Jasper G. Taylor III) "Privileges," at Norton Rose Fulbright and Deloitte Tax Controversy School, San Jose, California, October 10, 2017, and San Francisco, California, October 11, 2017.
- Presented "Federal Tax Practice Ethics and Circular 230" to Firm tax department, November 8, 2018.
- Presented "The Duty of Consistency and the Doctrine of Equitable Estoppel to Tax Executives Institute, Houston Chapter, March 4, 2021.
- Houston Bar Association - Taxation Section
- Treasurer (2003 - 2004)
- Secretary (2004 - 2005)
- Chair-Elect (2005 - 2006)
- Chair (2006 - 2007)
- State Bar of Texas - Tax Section
- Chair, Tax Controversy Committee (2013 - 2016)
- Co-Chair, Tax Controversy Committee (2016-2019)
- Council Member (2016-2019)
- Managed training for Firm tax associates, Spring 2013