Vivian D. Hoard, Esq.

Vivian Hoard helps solve complex tax controversy issues for both individual and business clients. By focusing her practice on civil and criminal tax controversy, tax litigation, whistleblower claims and voluntary offshore disclosures, Ms. Hoard has become a leader in the tax field. She has successfully represented individuals, small businesses and their owners, publicly traded companies, professional athletes and their agents, entertainers, lawyers and accountants. Ms. Hoard regularly consults with accounting firms during audits to help them and their clients understand their procedural options for resolving disputes at the lowest level possible. If the accountant is unable to resolve the matter, Ms. Hoard will assist the taxpayer and accountant with Internal Revenue Service (IRS) appeals and at the U.S. Tax Court or U.S. District Court. Most cases are successfully settled. Occasionally a case presenting a unique legal issue or an unresolved fact pattern must be tried. Ms. Hoard has successfully settled or tried civil tax controversies involving many varied tax issues, including tax shelter/sham transactions, conservation easements, family limited partnerships, excise taxes, passive loss issues, the civil fraud penalty, hobby loss issues, worker classification, trust fund liability, innocent spouse claims and much more. Ms. Hoard also has successfully represented taxpayers voluntarily disclosing offshore accounts and taxpayers targeted for criminal prosecution. No taxpayer may be prosecuted for a tax crime until the U.S. Justice Department approves the prosecution. Until that time, the investigation remains confidential. Ms. Hoard focuses on resolving criminal tax cases before they are referred for indictment and become public. Memberships State Bar of Georgia Atlanta Bar Association State Bar of Georgia, Taxation Law Section, Past Chair Atlanta Bar Association, Tax Law Section, Past Chair American Bar Association State Bar of Georgia, Children and the Courts Committee Community Involvement Leukemia & Lymphoma Society, TNT Participant, four endurance events Girl Scout Leader, 2007-2011 Northwest Presbyterian Church, Member