- Sean McMahon is a former Senior Attorney in the IRS Office of Chief Counsel. He is a former Special Assistant United States Attorney for the Districts of Massachusetts and New Hampshire, where he oversaw tax cases.He advises clients during exams and liability disputes, and where required, he litigates contested topics in court. As a former IRS attorney, Sean provides clients with unique insights into the real dangers involved in IRS disputes and sophisticated transaction preparation. He advises clients on the tax consequences of corporate, real estate, partnership, securities, and option transactions.Sean McMahon, Boston, has also assisted people with foreign transaction reporting and penalty issues, including foreign bank accounts and FBAR regulations.
Sean Area of Work
Sean assists individuals, estates, and corporations in all aspects of federal and state taxation, from audit through the collection. His areas of expertise include:
- Examination defence, including precise tax liability calculation and minimising penalties and interest
- Collections, such as instalment agreements, offer in concessions, and innocent spouse
- Appeals, including administrative appeals through the Office of Appeals and appeals to appellate courts
- Voluntary Disclosure, including assistance in bringing taxpayers who have not filed returns in several years into compliance; Foreign Bank Accounts and FBAR Requirements, including representation of US citizens with dual citizenship who have unreported foreign bank accounts and delinquent FBAR returns; and voluntary disclosure programmes
- Foreign trust and foreign corporate interest disclosure reports, as well as corresponding non-filing penalties, are required.
- Tax Litigation, involving tax issues before the United States Tax Court, United States District Courts, and the United States Court of Federal Claims
Sean also teaches a graduate-level tax practise and procedures course at Boston University School of Law.
Sean has over fifteen years of experience researching and defending IRS and state tax cases, and he specialises in resolving challenging and complicated tax disputes. He advises clients on the tax consequences of corporate, real estate, partnership, securities, and option transactions.Sean McMahon Boston has been recognised to the list of Massachusetts Super Lawyers in the field of taxation.Mr McMahon also represents clients in federal court on a variety of trademark and copyright issues.