SPEAKER_01: 0:01

And to be able to come in, diagnose the issue, and then help these business owners solve these issues, it's extremely rewarding and feel like I'm making a difference every day. The law license, right? And really going back to law school, and I think it's a unique experience when you're in law school, it's a cratic method, and you're kind of exposed to an area that you've never been exposed to in your life, and you go deep in it. I was fortunate to work while in law school, working for a law firm doing tax law, and as well as I did the tax clinic at University of Baltimore School of Law. And, you know, I think building that practical and deep knowledge in the actual practice of law, I think, yeah, coupled with law school and passing the bar, I think that portion was certainly the most difficult.

SPEAKER_00: 1:10

And of course, we share that same you bought law connection through Fred Brown. And Fred told me that while you were there, you founded the Business and Tax Law Association while you were a JD student. What were you trying to build before you could practice?

SPEAKER_01: 1:28

Yeah, absolutely. So I actually co-founded that with a great friend of mine, Giovanni Albertanza. And I was extremely tax focused at that time. And I think Giovanni, as well as Fred, convinced me to go much broader. They said, hey, if you just do tax law, nobody's going to come. So you should like really broaden this business and tax law association. But but what I was trying to do is bring people together in different disciplines, business lawyers, tax lawyers. And I've always done that with also trying to bring in CPAs, financial professionals, trying to get different perspectives on unique areas.

SPEAKER_00: 2:13

You started solo in 2007. Did you know while you were in law school, like this is what I want to do? I want to build this firm and scale it to 80 plus attorneys, or was it more let's see how this goes? And then it just kept getting better and better.

SPEAKER_01: 2:28

During law school, I was fortunate to have a great law clerkship with a tax law firm in Maryland. And I was a CPA while I was in law school. So that allowed me to administratively practice before the IRS and really learned a lot of that way. And worked for the same law firm all throughout law school, pretty much, and then joined a firm, Thomas and Libowitz in Baltimore, and then practiced there for close to a year, while licensed, and then went out, founded my own firm, and didn't know the size it was going to grow to, but just knew that we were going to try to do great things with clients and assist as many clients as possible.

SPEAKER_00: 3:15

It's unique because of the amount of CPAs you have working at your firm. What spurred that decision?

SPEAKER_01: 3:21

Yeah, I think it's always having both financial background as well as the legal background. It's always the lawyers are afraid of the accounting side, the accountants are afraid of the legal side, and really having both and to be able to combine both of those disciplines into one, I think just allows us to be better advocates for clients. It allows us to have deeper understanding of issues, and clients like to come to a place that understands both and can more efficiently and more practically solve a lot of client issues.

SPEAKER_00: 3:58

Who doesn't like a one-stop shop?

SPEAKER_01: 4:00

For sure.

SPEAKER_00: 4:00

Yeah. At the same time, I feel like you have to have a niche, but you've carved out a niche with that combination.

SPEAKER_01: 4:09

Yeah, and law has been very regulated. And in the past, there's certain regulations against multidisciplinary practices, certainly doing other things while in a law firm can be very regulated. It's unique when you're in an area such as tax law, because although we operate as a law firm, we're governed certainly by the Maryland Rules of Professional Conduct as well as other states' professional conducts. You're also practicing a lot of the time for the IRS administratively. And you're governed by kind of a different set of rules, you know, Circular 230, where enrolled agents, CPAs, et cetera, can all practice. So kind of a unique area in the text controversy relevant.

SPEAKER_00: 4:58

Yes. And those rules are not always easy to reconcile between CPAs and attorneys. You read one rule for a CPA and then an analogous rule, a parallel rule for an attorney. And it's like, I think those are not exactly conflicting, but don't offer the same guidance.

SPEAKER_01: 5:15

Yeah, and lawyers, we have a duty to be zealous advocates for our clients. Accountants have generally different duties, and it's generally not that. And especially if you're acting in the capacity of a return preparer, well, then you have certain duties to the client, you have certain duties to the government. You're kind of a quasi-government agent, you're in between both. But big picture, the law, the accounting, I think what we're starting to see in places like Arizona, Utah, starting to see private equity come into the industry. You're starting to see non-lawyer ownership of law firms. Both KPMG and Apri own started law firms in Arizona. You're going to see this multidisciplinary practice evolve and develop. And in fact, in Europe, many of the firms, the large big four accounting firms, they also practice.

SPEAKER_00: 6:14

Glenn, in practice, what does the CPA credential let you do that a pure tax attorney can't?

SPEAKER_01: 6:22

Yeah, the only thing a CPA credential can allow you to do, really, that a tax lawyer can't, is more so in the context of being an accounting firm where you can provide audit and a test services and you can sign financial statements, financial reports. Now, law firms typically can't do that. You've got to be a licensed CPA firm to do that. In the context of tax and tax controversy, certainly tax lawyers, enrolled agents can do the same that a CPA can do.

SPEAKER_00: 6:54

Who was the first attorney you brought on after being a solo practitioner?

SPEAKER_01: 6:58

I think I'll start with the first employee because she's still with me today, Caitlin Lossner, who at the time she was in law school, she had an accounting background, and I said, okay, well, you're gonna do half administrative, half legal type work, and she's always been a team player, and she did a great job all throughout law school work for me. And then we hired her as a full-time associate when she graduated, but she's an attorney, CPA, LLM, and tax, and also my law partner.

SPEAKER_00: 7:33

So she was in law school when you hired her initially. Yes. And then she's still with you today. How many years later?

SPEAKER_01: 7:40

Uh, I guess that would be 15 years later.

SPEAKER_00: 7:43

Wow. And did she have the same vision that you had for the practice throughout?

SPEAKER_01: 7:48

I don't think she has the same exact vision, but I think she compliments me extremely well. It's obviously good to have people around you that compliment you, that are good at skill sets that you're not good at. And I think she was on board and always been kind of an advocate for the mission. I've had more of that visionary role where she's been more execution.

SPEAKER_00: 8:11

With your respective business acumen between the two of you, how do your personalities differ?

SPEAKER_01: 8:17

I think she's she goes deep on things. She's very thoughtful, can come at things from which I think is good, is a healthy level of skepticism where she's trying to pick things apart and she sees situations in business that might have issues or might have red flags, and she identifies, you know, those certain circumstances of when we should go down a different path.

SPEAKER_00: 8:44

And Glenn, you you now have offices in seven plus states. At what point during your practice did you realize this has to expand and quickly?

SPEAKER_01: 8:54

You set up an office in a geographic region, and you realize, hey, there's great people all over. We're very fortunate in a practice area where we can primarily practice remotely. Very few clients that actually want to meet in person. Now, meet a couple clients a month in person. So it becomes very conducive, and especially after COVID, it became very conducive to hiring talent, just looking for where are the people located that we want to hire, that we want to work with, that have the talent to service our clients. And so it's just allowed us to not be restricted geographically. And you know, we have attorneys of many different states, and we'll continue to hire. I think if we were limited to just the DC, Maryland area and hiring, our talent tool just wouldn't be what it is.

SPEAKER_00: 9:46

Yeah, that opens up so many possibilities as far as who you can hire when you can hire from anywhere. Yeah, for sure. You've testified, Glenn, as an expert witness on criminal tax sentencing. What does the stand teach you about how judges think about tax crimes?

SPEAKER_01: 10:05

You have to really sometimes explain complexities and tax losses and things that normal people just don't really know. So it's it's just a matter of calm, cool, collected, and very, very well prepared in order to show them we've adequately prepared, we've understand the government's position, and here's the taxpayer's position.

SPEAKER_00: 10:32

Aaron Powell People think about tax loss. They think about actual tax loss and not um anticipated, expected. So that's a major distinction.

SPEAKER_01: 10:41

Sophisticated means enhancements, you know, all different types of analyses that have to be done in many different areas for sure.

SPEAKER_00: 10:49

Yeah. I mean the sentencing guidelines, the guidelines by itself, that's a pretty complex set of provisions. Then you add the tax code on top of that. It takes a different kind of individual to be able to decipher that.

SPEAKER_01: 11:03

Yeah, and that's where a tax controversy lawyer, criminal tax lawyer, can really add a lot of value is knowing that well, it's where a lot of value is added in the criminal tax realm.

SPEAKER_00: 11:14

Of course, we know that the tax division was recently dissolved. Where do you see tax enforcement heading within the next six to twelve months on the criminal side?

SPEAKER_01: 11:25

Yeah, I think on the criminal side, obviously you're gonna see less of just pure tax evasion. I think you're gonna see more focus in areas like COVID abuse, pandemic fraud, so PPP loans, employee retention credit, fraudulent claims. I think you're gonna see a real emphasis on some of the government programs and preparers along with individuals that were taking advantage of some of these programs. I think we'll see more and more of that, and that'll be the primary focus.