Chris Housh

Education

  • Golden Gate University, J.D.
  • Webster University, B.A.

Bar Admissions

  • California

Court Admissions

  • U.S. Tax Court
  • U.S. District Court – Northern District of California
  • U.S. District Court – Eastern District of California
  • U.S. District Court – Central District of California
  • U.S. District Court – Southern District of California
  • U.S. District Court — District of Nevada (pro hac vice)
  • Ninth Circuit Court of Appeals
  • United States Court of Federal Claims

Practice Areas

  • Tax Debt Collection and Resolution
  • State and Local Tax Disputes
  • Employment Tax / Payroll Tax Matters
  • Tax Levy Release and Modification
  • Tax Lien Subordination
  • Offer in Compromise
  • Installment Payment Agreement - High Dollar Balances
  • Penalty Abatement and Mitigation
  • Entity Formalities
  • Corporate Entity Formation and Dissolution
  • Corporate Revivors
  • Tax Audits and Appeals
  • Tax Litigation
  • State of California Sales Tax Audits, Appeals, and Litigation

Overview

An integral member of the Moskowitz team for more than 15 years, Chris has successfully negotiated resolutions for hundreds of clients facing challenging tax issues with the IRS and numerous state authorities. His highly customized approach has helped clients to achieve strong outcomes in difficult circumstances, save millions in tax obligations and penalties, and return to their regular lives and normal business operations. A wide range of business owners have also come to rely on Chris for his counsel on tax planning and compliance.

Unlike many other tax professionals, Chris is both a practicing attorney and enrolled agent. These qualifications enable Chris to represent clients in state and federal courts – including U.S. Tax Court – and to negotiate resolutions directly with the IRS and state taxing agencies across the country. Chris has particular experience representing taxpayers before California state tax authorities, including the Franchise Tax Board, Employment Development Department, and the Department of Taxes and Fee Administration (former Board of Equalization). He has also led negotiations with many state taxing authorities beyond California, including Nevada, Arizona, New York and Massachusetts.

In addition to negotiating resolution of disputes with tax authorities, Chris regularly advises business owners on tax planning and compliance. This includes advice on entity formation, compliance with requirements to maintain favorable tax status and protection from creditors, and reviewing annual performance to help businesses position themselves for continued growth. Chris also assists owners winding down operations, counseling on appropriate handling of assets and debts, and advising on filings to meet legal requirements. He also works on behalf of owners of now-dormant businesses, negotiating with authorities to resolve matters related to incomplete dissolution of business operations, including reduction of fees and penalties.

Chris’ highly customized approach stems from his belief that each case is unique. Both a careful listener and a quick study, Chris develops strategies to meet client-specific challenges and objectives to help ensure a more favorable resolution. A strong supporter of small business owners, Chris also places emphasis on ensuring clients emerge from tax challenges with a stronger understanding of their business and tax circumstances, with the goal of minimizing the risk of difficulty going forward.

Chris chairs the firm’s tax resolution and business entity compliance practice groups, and is a Vice President for the Golden Gate Society of Enrolled Agents. He has provided continuing education to other professional advisors on a variety of taxation topics, including employment tax and complex return preparation.

Experience

Chris has counseled clients on a variety of tax matters, including the following:

  • Federal, state, and local tax dispute resolution
  • Tax levy and lien resolution
  • Tax collection negotiations, including offers in compromise and installment payment agreements
  • Resolution of income, partnership, corporate, sales and payroll tax matters
  • California Franchise Tax Board disputes
  • California Department of Taxes and Fee Administration (Board of Equalization) disputes
  • California Employment Development Department disputes
  • Internal Revenue Service administrative hearings and appeals
  • Business tax compliance and planning
  • Business dissolution

Honors & Activities

  • President, Golden Gate Society of Enrolled Agents (2020 to present)
  • Vice President, Golden Gate Society of Enrolled Agents (2018-2020)
  • Director of Golden Gate Society of Enrolled Agents (2013-2015, 2017-2018)
  • Barristers Association of San Francisco, member
  • American Bar Association, member
  • California Association of Enrolled Agents (CSEA), member
  • National Association of Enrolled Agents (NAEA), member

Insights

Presentation:

  • State and Local Tax Compliance Issues, and Winding Down Business Considerations, Golden Gate University, School of Law, September 2021
  • IRS Collections Work: Some Interesting Observations, GGSEA Monthly Meeting, August 2018; Napa-Sonoma Society of Enrolled Agents Monthly Meeting November 2018.

Seminar:

  • Sales and Use Tax for Manufactures in California, Lorman Education, San Francisco, Dec. 2013
  • Independent Contractors v. Employee: Update on IRS 1099 Reporting, Lorman Education, November 2012

Professional Successes

  • Overturning a $400,000 IRS Penalty
    Chris’s client, a recent immigrant, reported a gift his father gave him and was assessed a $400,000 penalty by the IRS. Chris and his team discovered that the gift was made several months before his client received his Green Card and was therefore not subject to the penalty. They convinced the IRS to wipe it out.
  • Turning a $100,000 crisis into a $7,000 Annoyance
    The IRS took Chris’s client to tax court claiming he had underreported $100,000 because of an accounting procedure. Chris fought for a year and a half and got the matter resolved by moving $7,000 from one tax year to another.
  • Payroll Tax Relief
    Chris’s client, a business, owed the IRS $250,000 in back payroll taxes. Chris helped his client change payroll companies and persuaded the IRS to accept payments of $200 a month until his client got profits back in line.
  • Managing Business Debts Without Bankruptcy
    Chris’s client, a subcontracting company, owed a fortune they couldn’t pay. They owed the IRS $1.3 million and various other creditors $2.4 million. Chris and his team were able to dissolve the business, get the IRS to accept $200,000, and get the other creditors to accept $360,000. By using the tools of corporate dissolution, corporate formalities, and good faith negotiations, the business was able to avoid the public scrutiny of bankruptcy while closing the business.

Awards & Affiliations

Enrolled agent – authorized by the U.S. Treasury to practice before the IRS and all states recognizing the enrolled agent license
Board director, Golden Gate Society of Enrolled Agents 2017-present; 2013-2015