Lawrence (“Larry”) Sannicandro focuses his practice on federal and state tax controversies, including representation in audits, administrative appeals, collection matters, summons proceedings, and litigation in federal and state courts. He has extensive experience providing tax-related advice with respect to original tax return reporting positions on a broad range of substantive tax issues, amending tax returns, filing and litigating claims for refund, reporting foreign assets and income, making voluntary disclosures, and representing individuals in criminal tax investigations and prosecutions. Drawing on his unique experience as a former estate and gift tax attorney for the IRS, Larry is particularly well-versed in estate and gift tax planning techniques, as well as the valuation of closely held businesses. He also counsels clients on all facets of business and tax planning, including the formation, operation, transfer, and termination of business entities.
Larry serves the American Bar Association Section of Taxation as the Chair of the Tax Collection, Bankruptcy, and Workouts Committee. On behalf of the American Bar Association Section of Taxation, he has drafted comments to Congress and the IRS on a wide range of tax issues, such as reforming the procedures for auditing and litigating against partnerships and the need to adopt a voluntary disclosure program for unreported cryptocurrency transactions. For his service to the American Bar Association, Larry was awarded the John S. Nolan Fellowship. Larry also teaches a course in tax practice and procedure as an adjunct professor at Fairleigh Dickinson University, and he has taught classes on corporate tax, partnership tax, and negotiations as an adjunct professor at Pace University and a lecturer at Georgetown University Law Center and Rutgers Law School.
Larry is a dedicated pro bono advocate. He works with the After Innocence organization to provide tax-related advice to wrongfully convicted individuals, and he regularly appears on behalf of taxpayers as part of the New York County Lawyers’ Association’s U.S. Tax Court Calendar Call Program. The New York County Lawyers’ Association awarded Larry its Pro Bono Award.
Prior to entering private practice, Larry served as a law clerk for the United States Tax Court, and before that, as an attorney for the IRS. He earned his LL.M. in Taxation from Georgetown University Law Center, J.D. from the University of Florida Levin College of Law, and M.B.A. in Finance from Binghamton University. Larry is a frequent author on tax practice and procedure, having published articles in the Journal of Tax Practice and Procedure, Tax Notes®, TAXES – The Tax Magazine®, and The New Jersey Law Journal. He is the co-author of Qualified Appraiser, Qualified Appraisal: Practice, Procedure, Legal Analysis, and Theory (John Wiley & Sons, Inc. 2017), and Tax Practitioner’s Guide to Identity Theft (CCH, Inc. 1st ed. 2015; 2d ed. 2016). He is also a contributing author to Effectively Representing Your Client Before the IRS (Chapter 10).