Our Firm Lacey Strachan

strachan@taxlitigator.com Phone: (310) 281-3200
Fax: (310) 859-5115 Download Vcard

Lacey Strachan concentrates her practice in complex civil tax litigation and criminal tax prosecutions (jury and non-jury) before the federal district courts, the U.S. Tax Court, the U.S. Court of Federal Claims, and the Ninth Circuit Court of Appeals.  Ms. Strachan represents individuals, corporations, pass-through entities, trusts, and estates in all stages of state and federal tax disputes, including audits and examinations, administrative appeals, trials, and appellate litigation.

Ms. Strachan has been extremely successful in a wide range of sophisticated tax cases involving an array of substantive tax issues, including transfer pricing adjustments under section 482 for foreign related-party transactions, passive loss limitations for real estate investors, section 1031 transactions, bad debt deductions, deductibility of business expenses, substantiation of basis, characterization of shareholder loans, and accumulated earnings tax.  With a background in economics, Ms. Strachan is experienced in handling cases involving a variety of technical valuation issues relating to the fair market value of closely held businesses, real properties, artwork, and intellectual property assets.  A skilled advocate with a depth of knowledge of the tax code, she has extensive experience handling cases that present issues of first impression.

Ms. Strachan routinely represents and advises U.S. taxpayers in sensitive issue civil tax examinations involving both domestic and foreign tax-related issues where substantial civil penalty issues or possible assertions of fraudulent conduct may arise, and in defending criminal tax fraud investigations and prosecutions.  Ms. Strachan’s representative experience includes being one of the lead attorneys in a criminal tax trial that resulted in the acquittal of the client on all charges, where the client was tried on four felony counts stemming from two separate alleged conspiracies.  The acquittal was obtained after every other individual included in the indictment had pled guilty and the client’s former accountant had testified at trial as a cooperating witness for the prosecution.

Ms. Strachan graduated from New York University School of Law with an LL.M. in Taxation and received her J.D. from the University of Southern California, where she graduated Order of the Coif and was awarded the Deloitte Award for excellence in Corporate Taxation. While at USC, she was a senior content editor for the Southern California Law Review. Ms. Strachan graduated magna cum laude and Phi Beta Kappa from the University of California, Los Angeles with a B.A. in Business Economics.

Ms. Strachan serves on the Editorial Board for Los Angeles Lawyer magazine, the official publication of the Los Angeles County Bar Association.

Honors:

Ms. Strachan has been recognized as a Southern California Rising Star by Super Lawyers magazine every year since 2012.

Recent Speaking Engagements:

• Office of Tax Administration: Handling a Case Before California OTA, October, 2023
• Handling Estate and Gift Tax Audits, including Hot Topics in Enforcement and Valuation, November, 2022
• Office of Tax Administration: Handling a Case Before California OTA, August, 2022
• Criminal Tax Workshop, December, 2021
• Handling Estate and Gift Tax Audits including Hot Topics in Enforcement and Valuation and How is the Tax Court Responding, October 30, 2020
• Panelist, Handling Section 482 Transfer Pricing Controversies and the LB&I Inbound Distributor Campaign, Second Annual USD School of Law – RJS Law Tax Controversy Institute, August 11, 2017.
• Co-Speaker, The Life of an Estate Tax Case, Glendale Estate Planning Council, July 18, 2017.
• Panelist, When the Transaction Crosses the Border: What You Need to Know, USC Gould School of Law 2017 Tax Institute, January 24, 2017.

Recent Publications:

• “IRS Cracks Down on Tax Fraud by Creating a New Enforcement Office,” with Steven Toscher and Sandra Brown, Los Angeles Lawyer, June, 2020
• “Getting Ready to Defend the Material Participation IRS Examination,” Tax Notes, December, 2018
• “When the Transaction Crosses the Border – Globalization and the Changing Face of Tax Enforcement,” with Steven Toscher, Major Tax Planning: University of Southern California Gould School of Law Sixty-Ninth Institute on Federal Taxation, 2017.
• “Looking for Hidden Wealth: In Search of Beneficial Owners,” with Steven Toscher, Financier Worldwide Magazine, October 2016.
• “Transfer Pricing Issues Are Not Just the Problem of the Coca Cola’s of the World,” with Steven Toscher and Charles Rettig, New York University 74^th Institute on Federal Taxation, 2016.
• “The Tax Man Cometh – IRS Expansion of Section 482 Transfer Pricing Enforcement to Middle-Market Companies,” with Steven Toscher, Corporate Disputes Magazine, Jan-Mar 2016.
• “What You Need to Know About the Refund Statute of Limitations,” with Erin Collins and Edward M. Robbins, Bloomberg BNA Daily Tax Report, July 2014.
• “The New IRS Transfer Pricing Audit Roadmap—Where Will It Lead?” with Steven Toscher, Journal of Tax Practice and Procedure, April-May 2014.
• “Waiving a Jury in a Criminal Tax Case: Some Observations,” with Steven Toscher, Journal of Tax Practice and Procedure, December 2013-January 2014.
• “Proving Wilfullness in Civil FBAR Cases,” with Steven Toscher, Los Angeles Lawyer, April 2013.
• “Signing a Tax Return is Not Enough – Proving Willfulness in an FBAR Case Requires Other Surrounding Facts and Circumstances,” with Steven Toscher, Journal of Tax Practice and Procedure, April-May 2012.
• “Proving Willfulness in an FBAR Case,” with Steven Toscher, Journal of Tax Practice and Procedure, April-May 2012.

Education:

• New York University (LL.M. in Taxation)
• University of Southern California (J.D., Order of the Coif)
• University of California, Los Angeles (B.A., Business Economics, College Honors, Phi Beta Kappa)

Bar Admittance:

• Supreme Court of California
• Supreme Court of the United States
• U.S. Court of Appeals, Ninth Circuit
• U.S. District Court, Central, Eastern, Northern and Southern Districts of California
• U.S. Tax Court
• U.S. Court of Federal Claims

Professional Affiliations:

• American Bar Association, Section of Taxation, Member
• State Bar of California, Taxation Section, Member
• Los Angeles County Bar Association, Taxation Section, Member
• Beverly Hills Bar Association, Taxation Section and Entertainment Section, Member