Stephen Josey helps high-net-worth individuals, executives, family offices, fiduciaries, and businesses resolve their most sensitive and consequential tax disputes with the IRS and the U.S. Department of Justice. A Chambers-ranked private client tax controversy lawyer, Stephen represents clients in examinations, administrative appeals, government investigations, and litigation — often where substantial financial exposure, reputational sensitivity, or allegations of fraud raise the stakes. He also counsels clients on return positions and audit readiness following liquidity events and other wealth-generating transactions.
Stephen brings a litigator’s mindset to tax disputes. He is willing to test the government’s factual and legal positions, asserted burdens, and compliance with statutory and administrative requirements. His recent work has focused on taxpayer confidentiality, unauthorized disclosures of return information, penalty-imposition procedures, and agency compliance with the Administrative Procedure Act — areas where the outcome can turn as much on the government’s adherence to its own procedures as on the transaction or reporting position under scrutiny. His litigation experience spans the U.S. Tax Court, federal district courts, the U.S. Court of Federal Claims, and federal courts of appeals.
Stephen built his private practice within several of the nation’s leading tax controversy teams. Earlier in his career, he served as a trial attorney in the DOJ’s Tax Division, which he joined through the Attorney General’s Honors Program and where he received the Outstanding Attorney Award, and later in the Civil Division’s Commercial Litigation Branch. He draws on that experience to anticipate how the government builds and evaluates cases and to identify where its positions are vulnerable. Immediately after law school, he clerked for the Hon. J. Daniel Breen of the U.S. District Court for the Western District of Tennessee.