Giovanni V. Alberotanza - Partner
Giovanni Alberotanza is an attorney in Rosenberg Martin Greenberg’s nationally-recognized tax controversy department. His practice focuses on the representation of individuals and businesses throughout all stages of civil and criminal federal and state tax controversies, including litigation in federal and state courts.
He joined the firm in January 2010, practicing law while simultaneously pursuing his Master of Laws in Taxation (LL.M.). Rounding out his business tax practice as well as his experience in accounting and finance, Giovanni obtained a Master of Business Administration (M.B.A.) in 2011. After practicing law with the firm for over a year and a half, he accepted a two-year position in Washington, DC as an attorney-adviser with the United States Tax Court. Giovanni returned to the firm in 2013 and applies his broad experiences to guide individuals and businesses through a wide-range of complex tax issues.
Giovanni earned his Juris Doctor from the University of Baltimore School of Law where he served on the editorial board of the University of Baltimore Law Review, the National Civil Rights Moot Court Team, and as a Litigation Fellow with the Snyder Center for Litigation Skills. He earned his Master of Laws in Taxation from the Georgetown University Law Center in Washington, D.C. where he served as a Case Note Mentor for The Tax Lawyer, a nationally recognized legal journal published by the American Bar Association. He frequently dedicates his spare time to community and charitable events in the Baltimore / Washington metropolitan area.
Recent Speaking Engagements
- American Bar Association Section of Taxation 2018 Mid-Year Meeting – Panelist, “IRS Transcripts & Federal Statutes of Limitation,” San Diego, CA (February 2018)
- Maryland Volunteer Lawyer Services (MVLS) – Speaker, webinar “IRS Liens and Levies” (December 2017)
- Maryland Society of Accountants and Tax Professionals (MSATP) – Speaker, “Collection Matters with the IRS,” Frederick, MD (November 2017)
- Maryland Association of Certified Public Accountants (MACPA) – Panelist, “Employment Tax Enforcement,” Annapolis, MD (September 2017)
- American Bar Association Section of Taxation 2017 Joint Fall Meeting – Panelist, “How to Represent Taxpayers in Collection Matters From the Notice and Demand Through the Notice of Determination,” Austin, TX (September 2017)
- American Bar Association Section of Taxation 2017 May Meeting - Panelist, "Expert Witnesses in Tax Controversies," Washington, DC (May 2017)
- Federal Bar Association Tax Law Conference, Enforcement & Criminal Tax Program - Panelist, "Life of a Criminal Tax Case: Investigation Stage," Washington, DC (March 2017)
- American Bar Association Section of Taxation 2017 Mid-Year Meeting - Panelist, "Tax Court 101: Expert Witnesses - Discussion and Demonstration," Orlando, FL (January 2017)
- Maryland Association of Certified Public Accountants (MACPA) – Panelist, “Tax Controversy Seminar,” Annapolis, MD (August 2016)
- Bloomberg BNA – Webinar Panelist, “The Nuts and Bolts of a Criminal Tax Case” (July 2016)
- American Institute of Certified Public Accountants (AICPA) – Webinar Panelist, “Stages and Strategies in a Criminal Tax Case” (July 2016)
- The Knowledge Group – Webinar Panelist, “IRS Offshore Voluntary Disclosures: What’s Next in Disclosing Offshore Accounts?” (June 2016)
- American Bar Association Section of Taxation 2016 May Meeting - Moderator, “The Administrative Tax Collection Case,” Washington, DC (May 2016)
- American Bar Association Section of Taxation's 2nd Annual Young Tax Lawyers Symposium - Panelist, "Evolution of a Criminal Tax Case," Washington, DC (April 2016)
Recent Criminal Matters*
- Represented a restaurant owner who was the subject of a criminal tax investigation by the IRS Criminal Investigation Division. The IRS was persuaded not to bring criminal charges against his client.
- Represented Maryland tax return preparer under criminal investigation by the Maryland Comptroller and Maryland Attorney General for state criminal tax offenses.
Recent Civil Matters*
- Represented a taxpayer in litigation before the United States Tax Court in a tax deficiency matter related to business debt. The IRS sought to hold the client liable for taxes, penalties, and interest in excess of $1.6 million. Successfully convinced the IRS to concede the case resulting in no taxes, penalties or interest due from his client.
- Represented a business in sales tax litigation involving the District of Columbia Office of Tax and Revenue (OTR). Participated in multiple hearings and conducted numerous depositions of government officials, ultimately convincing the OTR to settle a proposed tax liability of approximately $340,000 for $20,000.
- Represented an individual before the United States Tax Court. The IRS sought to hold the client liable for taxes and interest in excess of $250,000 related to four tax years. Obtained innocent spouse relief for the client before trial which resulted in no tax or interest due from his client.
- Defended an upscale Washington, DC nightclub in an IRS employment tax audit. Negotiated a favorable settlement with the IRS while successfully persuading the Revenue Agent not to expand the audit to other businesses owned by his clients.
- Represented the estate of a deceased attorney before the IRS Office of Appeals. Successfully negotiated a favorable settlement, reducing a proposed tax assessment of over $461,000 to $19,000.
Other Representative Matters*
Offshore and Domestic Voluntary Disclosures
- Represented numerous individuals in the 2011 Offshore Voluntary Disclosure Initiative (OVDI), 2012 Offshore Voluntary Disclosure Program (2012 OVDP), and 2014 Offshore Voluntary Disclosure Program (2014 OVDP).
- Represented individuals utilizing Streamlined Domestic Offshore Procedures, Streamlined Foreign Offshore Procedures, Delinquent International Information Return Submission Procedures, and Delinquent FBAR Submission Procedures.
- Represented individuals with offshore tax matters before the Comptroller of Maryland.
- Represented individuals with interests in Controlled Foreign Corporations (CFCs), foreign trusts, Passive Foreign Investment Companies (PFICs), foreign pensions, and foreign annuities.
- Experienced with compliance and preparation of schedules and forms for offshore investments and businesses, including all aspects of Form 8621, Form 8938, and FBARs.
- Represented individuals and businesses with potential criminal exposure related to domestic tax issues, guiding them through the IRS's Domestic Voluntary Disclosure Practice and corresponding state practices.
Audits and Appeals
- Represented individuals and businesses through administrative appeals with the IRS Office of Appeals, Maryland Comptroller’s Office of Hearings and Appeals, and District of Columbia Office of Administrative Hearings. Successfully argued for reductions or elimination of assessments related to various substantive tax issues.
- Represented employee benefits plan in IRS examination. Worked directly with revenue agent to resolve the examination with no changes.
Tax Collection Solutions
- Represented individuals and businesses with tax collection issues. Defended taxpayers facing enforced federal and state collection action including levies, liens, and wage garnishments.
- Negotiated collection alternatives for individuals and businesses with the IRS and Comptroller of Maryland, including Offers in Compromise and installment agreements.
Other Administrative Matters
- Represented individuals and businesses with administrative claims for refund against the IRS. Successfully argued for, and obtained, a large refund for a Maryland Neonatal Intensive Care Unit nurse pursuant to Internal Revenue Code section 108.
- Represented individuals before the Maryland Department of Business and Economic Development and the Maryland Comptroller’s Office of Hearings and Appeals with respect to the revocation of a claimed Maryland Biotechnology Investment Incentive Tax Credit.
- Represented individuals and businesses in penalty abatement requests with the IRS, the Maryland Comptroller, and the District of Columbia Office of Tax and Revenue. Successfully convinced the IRS to waive all penalties assessed against his client, a well-known bakery business.
- Represented taxpayers facing summons enforcement action in U.S. District Court.
*Past results do not guarantee future outcomes as every individual case stands on its own facts and circumstances.
- University of Baltimore Merrick School of Business / Towson University College of Business and Economics, M.B.A. (2011)
- Georgetown University Law Center, LL.M. in Taxation (2010)
- University of Baltimore School of Law, J.D. (Honors) (2009)
- Towson University, B.A., Dual Degree: Economics and Political Science (Honors) (2005)
- District of Columbia
- United States Supreme Court
- United States District Court, District of Maryland
- United States Bankruptcy Court, District of Maryland
- United States Tax Court
- United States Court of Federal Claims
- United States Court of Appeals, Fourth Circuit