Brock E. Whalen Austin

Brock E. Whalen joined Ryan Law after having been a trial attorney with the IRS Office of Chief Counsel for over 12 years. As an Associate Area Counsel, he was the first-line supervisor of a staff of attorneys and paralegals responsible for litigating cases before the U.S. Tax Court and providing legal advice to the Examination and Collection functions of the IRS. In that role, he was the government’s supervisor for over twenty trial sessions overseeing the preparation of hundreds of cases for trial and was the government’s primary point of contact for the Tax Court for each session. Apart from his managerial duties, he served as a member of several select Chief Counsel groups that supported IRS initiatives including syndicated conservation easements and inbound withholding, and was the head of his area’s passthrough cadre, which provided advice to IRS subject matter experts and Counsel attorneys regarding partnership and S corporation tax issues.

As a trial attorney with Chief Counsel, Brock litigated income tax, estate and gift tax, Collection Due Process, TEFRA, and listed transactions issues. He also represented the United States in District Court as a Special Assistant United States Attorney in IRS summons enforcement suits.

Brock has made numerous presentations to IRS personnel, Chief Counsel attorneys, and private practitioners concerning topics such as: Codification of the Economic Substance Doctrine under I.R.C. § 7701(o); Tax Fraud; Burden of Proof in Tax Court; Evidentiary Considerations in Tax Court; Tax Court Rule Changes; Judicial Anti-Abuse Doctrines; Managerial Approval of Penalties Under I.R.C. § 6751(b); Passport Restrictions for Seriously Delinquent Tax Debts; Community Property Law and Federal Taxes; and IRS Summons Enforcement and Interview Techniques.