Lawrence (Larry) Sannicandro focuses his practice on federal and state tax controversies, including representation in audits, administrative appeals, collection matters, summons proceedings, criminal tax investigations and prosecutions, and litigation in the United States Tax Court, federal district and appellate courts, and state tax tribunals. 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, challenging civil tax penalties, reporting foreign assets and income, and making voluntary disclosures.
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, and defending those techniques and valuations in disputes with tax authorities. He also counsels clients on all facets of estate, business, and tax planning, including the formation, operation, transfer, and termination of business entities.
Larry is a member of the Internal Revenue Service Advisory Council (IRSAC) and a fellow of the American College of Tax Counsel. He serves the American Bar Association (ABA) Section of Taxation as a vice chair of the Court Procedure and Practice Committee as well as a member of the Appointments to the Tax Court Committee. He was also a past Chair of the ABA Section of Taxation’s Committee on Tax Collection, Bankruptcy and Workouts. On behalf of the Tax Section, he has drafted comments to Congress, the IRS, the Treasury Department, and the United States Tax Court 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.
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, legal ethics, 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 who uses his tax expertise to give back to the community. He works with the After Innocence organization to provide tax-related advice to wrongfully convicted individuals. For his work in co-designing and co-implementing an entirely new form of low-income taxpayer assistance, the ABA Section of Taxation awarded Larry the 2020 Janet Spragens Pro Bono award, the Section of Taxation’s highest award for pro bono. Larry also 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 in 2015. Larry is a member of the Supreme Court of New Jersey District VA Ethics Committee, and he proudly serves as a trustee of Integrity House, one of the largest non-profit providers of substance use disorder treatment in New Jersey.
Prior to entering private practice, Larry served as a law clerk for the United States Tax Court. He earned his LLM in Taxation from Georgetown University Law Center, his JD from the University of Florida Levin College of Law, and his MBA 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 (including Tax Notes State), TAXES – The Tax Magazine®, and The New Jersey Law Journal, among other regarded periodicals. He is the author of the BNA Tax Management Portfolio on Innocent Spouse and a 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 the Effectively Representing Your Client Before the IRS (Chapter 10 of the ABA Section of Taxation’s book).