Overview

Trisha Farrow is a former Internal Revenue Service senior trial attorney with experience in cases involving captive insurance, research and development credits, tax promoter penalties, fraud, and the application of the Tax Code to the cannabis industry.

During her eight years at the IRS, she provided advice to revenue officers and agents on tax and collection issues that included summons enforcement, lien priority, and whipsaw positions. At the IRS, she received the Lucite Award recognizing her achievement in successfully litigating a case involving tax promoter penalties and developing favorable case law.

While at the IRS, she oversaw and advised IRS revenue agents and officers across the Western United States on fraud penalty development, research and development credits, and I.R.C. § 280E cannabis related issues. Trisha was also an instructor at a national course designed to train IRS trial attorneys in litigation strategy and trial practice.

Since her service as a senior trial attorney at the IRS, Trisha has worked to defend, and obtain successful results for her clients, including:

• Obtaining total defense jury verdict against the IRS and United States in trial involving millions in penalties for allegedly knowingly failing to report foreign bank accounts;
• Overturning the long-established jurisdictional Tax Court petition filing deadline through briefs and oral argument in the Second Circuit Court of Appeals;
• Successfully obtaining millions of dollars in ERC refund suit;
• Reducing and eliminating proposed tax deficiencies and penalties based on allegations of fraud, unreported gambling winnings, unsubstantiated business deductions, unreported digital currency income.