Chuck Hurley is a tax controversy lawyer and practices in Norton Rose Fulbright's Washington, DC office.
He advises clients on tax litigation matters from a wide range of industries, including consumer products, financial products, technology, energy and professional services. His experience also includes IRS audits and appeals, tax consulting and planning, government relations, research and development tax credits and IRS summons enforcement.
Prior to entering private practice in tax controversy, Chuck spent more than 13 years (1990–2003) with the US Department of Justice's Tax Division, where he was responsible for preparing and conducting significant tax trials involving document-intensive, complex disputes. Chuck held first chair on two of the Tax Division's most prominent cases: Long-Term Capital Holdings v. United States and Trigon Insurance Co. v. United States.
In addition, Chuck served as first chair on more than 20 other jury and bench trials dealing with tax-related issues. He was also lead counsel on numerous other cases that were resolved short of trial by motion or settlement, and he handled significant evidentiary hearings regarding injunctions and summons enforcement proceedings.
During the course of his career, Chuck has taken and defended hundreds of depositions involving both fact and expert witnesses, including depositions taken in the UK, Puerto Rico and the Cayman Islands. He has argued numerous motions in court dealing with a wide variety of topics, including issues of privilege.
Over the course of his career, Chuck has worked with more than 100 expert witnesses to develop their expert opinions and reports in the various matters for which he has been responsible. These experts include economists, accountants, valuation experts and engineers. Also, Chuck has both filed and defended against Daubert motions (motions that challenge the reliability of expert testimony).
In addition to the Tax Court, Chuck has appeared in U.S. District and Bankruptcy courts located in 17 different states, including Ohio, New York, California, Connecticut, Vermont, Illinois, Virginia, Pennsylvania, Minnesota, Georgia, Iowa, North Carolina, Missouri, Oklahoma, Kansas, South Dakota and Arkansas. He has also appeared in several state courts, located in Ohio, New Jersey and Oklahoma.
In addition to his trial experience, Chuck has had significant success in negotiating favorable resolutions short of trial. In one notable case, Chuck negotiated a settlement in which the IRS agreed to sustain more than $45 billion in contested deductions. In another case, after walking government counsel through a forensic accounting analysis developed for trial, Chuck persuaded the Tax Division of the Justice Department to concede a case involving $227 million in deductions the IRS had contested on economic substance grounds.
Prior to his work with the Department of Justice, Chuck held positions with two other prominent law firms. Earlier, he served as Law Clerk to The Honorable Alvin I. Krenzler, US District Court for the Northern District of Ohio.