Our Firm Cory Stigile

stigile@taxlitigator.com Phone: (310) 966-7806
Fax: (310) 859-5131 Download Vcard

Cory Stigile specializes in tax controversies as well as business and international tax. His representation includes federal and state tax controversy matters, including sensitive tax-related examinations and investigations for individuals, partnerships, limited liability companies, and corporations. His practice also includes complex civil tax examinations, administrative appeals and tax collection proceedings (where he is widely respected for achieving meaningful resolutions of difficult tax collection issues). He has litigated cases in the U.S. Tax Court, the U.S. District Court, the Court of Federal Claims and the 9th Circuit Court of Appeals.

Mr. Stigile is a Certified Specialist, Taxation Law, The State Bar of California, Board of Legal Specialization. Mr. Stigile is also a CPA licensed in California.

Prior to practicing as an attorney, Mr. Stigile practiced in public accounting at KPMG LLP in federal taxation and then assurance. During law school, Mr. Stigile was a field placement intern with the IRS.

Organizations:

• AICPA Tax Practice and Procedures Committee Member (2018-2021)
• AICPA Advocacy & Relations Committee Member (2021-2023)
• California Society of Certified Public Accountants
• AICPA Council (2016-2022)
• Committee on Taxation Member (2019-2023), State Subcommittee Chair (2021-2023)
• Member at Large of CalCPA Board of Directors (2014-2016)
  • President, Los Angeles Chapter (2013-2014)
  • First Vice President, Los Angeles Chapter (2012-2013)
• CalCPA Leadership Institute (2012)
  • Vice President, Los Angeles Chapter (2010-2012)
  • Council (2009-2013)
• Nominations Committee, State Board (2010-2012)
• Treasurer, Los Angeles Chapter (2009-2010)
• Los Angeles Chapter Board (2008-2013)
• American Bar Association, Taxation Section
  • Co-Chair, Criminal Tax Penalties Subcommittee of CCTP (2010-2016)
  • Civil & Criminal Tax Penalties Committee (CCTP) (2006)
• Western States Bar Association Member (2012-2013)
• Los Angeles County Bar Association
  • Tax Procedure and Litigation Committee (Chair, 2007)
• Washington D.C. Delegation Presenter of Paper on Collection Due Process (2007)
• Annual UCLA Extension Tax Controversy Institute – Conference Planning Committee Member (2010-2012)
• Beverly Hills Bar Association
• PADI Foundation, President (2018-2022)

Education:

• LL.M., Taxation, New York University
• J.D., Emory University
  • B.S., Accounting, California Lutheran University cum laude
  • Minor in Philosophy

Representative Presentations:

Mr. Stigile frequently writes and lectures on topics involving taxation. His more recent speaking engagements include “Navigating IRS Corporate and High-Income Taxpayer Audits: Key Areas of Focus for Examinations, Pitfalls to Avoid,” for Strafford, “Global High Wealth Audits” and “Ethical Issues for Tax Professionals,” for Oregon State Tax Update, “Ethical Issues for Tax “Handling the New IRS Global Wealth Examinations,” for CalCPA, “Valuation in Tax Cases – Best Practices and Emerging Issues,” for UCLA 39th Annual Tax Controversy Institute, “Partnership Losses in Excess of Basis: Preparing for the IRS Audit Campaign,” for Strafford, “IRS High-Wealth Examinations: IRS Wealth Squad, Targeted Issues, Preparation,” for Strafford, “Internal Revenue Service Scrutiny of the ERC,” for Orange County Bar Association, “The Ins and Outs of Tax Audits,” for Beverly Hills Bar Association, “Collection & Offer Specialist Panel & an IRS Campaign,” for UCLA 38th Annual Tax Controversy Institute, “Research and Development Tax Credits: IRS Scrutiny of Qualified Research Activity and Related Expenses,” for Spidell, “Partnership Losses in Excess of Basis: Preparing for the IRS’ New Audit Campaign,” for Strafford, “Currency Transaction Report: How to File and Common Errors,” for Lorman Educational Services, “Research and Development Tax Credits: IRS Scrutiny of Qualified Research Activity and Related Expenses,” for Strafford, “IRS High-Wealth Examinations: IRS Wealth Squad, Targeted Issues, Preparation, IDRs, Appeals and Litigation,” for Strafford, “Advising High Income Non-Filers, Voluntary Disclosure and Collection Issues,” for CalCPA, “Handling the New IRS Global High Wealth Examinations,” for CalCPA, “Cryptocurrency Tax Compliance in the Post $50,000 Bitcoin World,” for AAA-CPA Annual Conference, “High Income Non-Filers: Handling IRS Examinations, Voluntary Disclosure Program, Criminal Investigations,” for Strafford, “Handling the New IRS Global High Wealth Examinations,” for CalCPA, “High Net Worth Audits,” for Spidell, “IRS Audits: Responding to IDRs, Independent Office of Appeals, Extending the Statute, and Current IRS Initiatives,” for Strafford, COVID-19 Administrative and Legislative Relief,” for Beverly Hills Bar Association,  “Back to Basics on The Ethics of Federal Tax Practice:  Best Practices 101 for the American Bar Association Tax Section,  an “Income Tax Update” for California State University, Los Angeles, “Tax Identity Theft” for the Taxation Technical Committee of the Los Angeles Chapter of CalCPA, “The Administrative Tax Controversy Case from Examination to Appeals” for the ABA Tax Section, “Best Practices in “Settling” Cases with the IRS and FTB for the Glendale Estate Planning Counsel, the “IRS Audit Programs and Other Hot Tax Controversy Issues” for the Santa Clarita Valley Discussion Group of the Los Angeles Chapter of CalCPA, “Updates on Civil and Criminal Tax (Federal) for the Best of CLE program in Santa Monica, California, and the “Tips and Tricks for IRS, FTB & SBE Settlements” panel at the Los Angeles County Bar Association Practitioner’s Conference.  He was also interviewed by Bloomberg Law regarding IRS Wealth Squad audits focusing on the super-rich.  Mr. Stigile was awarded the distinction of Super Lawyer Rising Star in 2012 through 2016, as recognized and published in Los Angeles Magazine. He is also on the Planning Committee of the Annual UCLA Extension Tax Controversy Institute and a member of the Western States Bar Association.

Publications:

• Author, “Considerations for IRS examinations of ERC claims,” The Tax Adviser, July, 2023
• Co-Author, “2020 and 2021 Residency Cases Before the OTA,” CalCPA Committee on Taxation State
  Subcommittee Report, May, 2021.
• Author, “Enlist an ally in TAS,” Journal of Accountancy, January 1, 2021.
• Author, “Nexus Considerations, Teleworking During COVID-19: FTB FAQs Issued,” California CPA,
  November 2020.
• Author, “Resolving IRS Hardships with the National Taxpayer Advocate Service,” The Tax Advisor,
  October 2020
• Co-author, “Foreign gifts: A common example of undisclosed foreign transactions,” Tax Insider, March 12, 2020
• Author, “Now I Am a C Corp: What About the Accumulated Earnings Tax?” Tax Notes Today, April 15,
  2019
• Author, “First-Time Abatement: Procedure and Case Law Updates,” The Tax Advisor, July 2018
  Co-author, “Will the Real John Doe Please Stand Up? Tax Identity Theft Developments,” Journal of Tax Practice and Procedure, February-March 2012
• Co-author, “Important Developments During the Year – Important Criminal Developments,” The Tax
  Lawyer, 2010-2012
• Author, Collection Due Process – The Administrative Record for Tax Court Proceedings (2007)
  Co-author, “The Effects of a Federal Tax Adjustment by the Internal Revenue Service on a California
  Personal Resident,” California Tax Lawyer, Spring 2006
• Co-author, “Strategic Options for Taxpayers – California Tax Procedure 101,” California Tax Lawyer,
  Winter 2006
• Co-author, “Important Developments During the Year – Important Civil Developments,” The Tax Lawyer, Summer 2006
•