Matthew David Carlson

Matt Carlson represents businesses and individuals with regard to a wide range of tax matters.  Prior to entering private practice, Matt worked as a trial attorney for the IRS Office of Chief Counsel where he was assigned to the Small Business/Self-Employed division. Matt has litigated hundreds of cases in the United States Tax Court and has had twenty five Tax Court bench trials.  Matt has litigated a wide range of substantive tax issues including unreported income, characterization of income, capital gain issues, treatment of settlement proceeds, theft loss deductions, bad debt deductions, charitable contributions, gambling losses, rental property matters, self-employment tax issues, and various income and deduction issues for partnerships, LLCs, sole proprietorships, S corporations and C corporations. He has also litigated unique legal issues such as conservation easement deduction valuation and substantiation requirements, S Corporation income-shifting arrangements, treatment of stock transfers in a 90% stock loan program, tax preparer penalties and injunction cases.

Additionally, Matt has significant experience in procedural tax issues including innocent spouse relief, collection due process hearings and litigation, interest abatement, penalty assessment, statutes of limitations, TEFRA matters, summons enforcement issues, Circular 230 disputes and various jurisdictional issues.

Matt was also appointed by the U.S. Attorney's Office as a Special Assistant U.S. Attorney to represent the United States on behalf of the IRS in Bankruptcy Court. During the course of his appointment, Matt litigated adversarial proceedings, objections to claims, objections to plan confirmations, motions to dismiss, and dischargeability issues. In addition to his work for the Small Business/Self-Employed Division and U.S. Attorney's Office, Matt performed cross-divisional work assignments for the Large Business and International division as well as the Criminal Tax and Tax-Exempt/Government Entities divisions.

Matt has been admitted to practice by the State Bar of California, by the Eastern and Northern Districts of the United States District Court in California, and by the United States Tax Court. Matt earned his Juris Doctor degree with a Tax Concentration from the University of the Pacific, McGeorge School of Law where he was a Law Review writer and editor, a member of the Roger J. Traynor Honor Society, and earned the prestigious Witkin Award in Torts. Prior to attending law school, Matt received his Bachelor's Degree in Business Administration with a minor in Economics from Sonoma State University.

Prior to practicing law, Matt served the California Department of Corporations' Office of Law and Legislation analyzing legislation and drafting protocol for financial privacy law compliance. Matt also assisted the California Environmental Protection Agency's Department of Toxic Substances Control by writing legal memoranda on issues related to environmental and administrative law. Matt's interests include travel, cycling and snowboarding.