Daniel N. Price

Dan’s legal practice focuses on tax and Title 31 (Bank Secrecy Act) controversy matters with the IRS and tax matters before certain state tax authorities. For over nineteen years, Dan served as an attorney for the Office of Chief Counsel of the Internal Revenue Service. As a former trial attorney and manager (supervisory trial attorney) with the Office of Chief Counsel and as a Special Assistant United States Attorney, Dan has had unique experience with tax controversy and tax administration.  ​

Dan’s prior government service included extensive work in the arena of international enforcement and included assisting the IRS in completely revising the Voluntary Disclosure Practice. Dan also worked with the Offshore Voluntary Disclosure Programs, the Streamlined Filing Compliance Procedures, foreign bank account reporting, Bank Secrecy Act investigations, various LB&I compliance campaigns, expatriation issues, international collection of taxes, and much more. Dan served as a Chief Counsel “FBAR Coordinator” reviewing willful FBAR penalty cases proposed by IRS revenue agents. Dan was also part of the Chief Counsel team who met quarterly with the Department of Justice Tax Division on FBAR cases and annually on significant international enforcement matters.  

In July of 2014, the Chief Counsel appointed Dan the Managing Counsel of the Austin, Texas, post of duty. Dan also provided countless training sessions to IRS and Chief Counsel personnel across the United States and Puerto Rico and taught as an instructor in Chief Counsel schools such as Discovery School and Advanced Trial Advocacy School. Dan also served as a spokesperson for the IRS, giving presentations in the United States, Mexico, and Canada on international compliance issues. Dan had a truly rare, well-rounded career with the Office of Chief Counsel. He tried many cases as a trial attorney, managed paralegals and attorneys, and departed the government at the end of 2021 as a valued member of the teams overseeing the Voluntary Disclosure Practice, the Streamlined Filing Compliance Procedures, the Relief Procedures for Certain Former Citizens, and other projects with national and international scope.

Beyond Dan’s normal tax practice, he has an active pro bono practice in both tax, immigration asylum, and other matters. Dan spent the year 2022 volunteering his legal services as in-house counsel with a nonprofit. In the tax realm, Dan has represented low-income taxpayers pro bono in Tax Court proceedings and in administrative proceedings including abatement requests of unjustified international information return penalties. Dan taught in a tax webinar on tax compliance issues for refugees; the webinar was tailored to help volunteer tax return preparers assisting asylum seekers. Dan also volunteers as a member of the Form 3520 Task Force of the American Institute of Certified Public Accountants (AICPA).  

In immigration asylum matters, Dan has handled defensive asylum claims in Immigration Court removal proceedings and affirmative asylum claims before the U.S.C.I.S. The San Diego Union-Tribune published articles written by the esteemed immigration reporter Kate Morrisey on January 1, 2023, and January 14, 2023, featuring one of Dan’s asylum cases in Immigration Court in San Diego. Ms. Morrisey’s January 14, 2023, article quoted Immigration Court Judge Scott Simpson regarding Dan’s work: “Through the assistance of your attorney, this has been the most well-documented asylum case I have ever seen.”  

Dan occasionally writes tax related articles and blog posts including for Tax Notes and Procedurally Taxing. Here’s a link to the Nov./Dec. 2022 issue of the EA Journal which featured Dan’s cover article When Your Client Says, “I’ll Fake a Receipt.”

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Dan also provides input to the government in response to certain matters such as:

• Dan's letter dated July 3, 2023 in response to proposed Treasury Regulations under I.R.C. sec. 6571(b)

• Dan’s letter dated February 9, 2023 in response to the IRS’ December 2022 request for public comments on Forms 3520 and 3520-A