Miller & Chevalier Adds Thomas Zehnle to Tax and White Collar Practices

Brings Significant Tax Defense and Investigation Experience; Deepens Firm's Capabilities in Criminal Tax and White Collar Areas

Washington, D.C., January 25, 2011 – Miller & Chevalier Chartered today announced that Thomas E. Zehnle has joined the firm's Tax and White Collar and Internal Investigations practices as a Member. Zehnle joins the firm from Bryan Cave LLP, where he was a partner in the Washington, D.C. office.

The addition of Zehnle is a reflection of the firm's ongoing strategy of expanding and deepening its core practices to meet the complex legal needs of its clients in an environment characterized by increased government scrutiny and enforcement. Zehnle brings almost 25 years of experience in white collar criminal litigation, having served as Chief of the Criminal Enforcement Section (Southern) of the U.S. Department of Justice (DOJ), Tax Division, a federal tax prosecutor, and a white collar defense lawyer.

"As a white collar defense lawyer and federal prosecutor, Tom has handled hundreds of investigations and trials involving allegations of tax fraud, conspiracy, money laundering, securities, and Bank Secrecy Act violations, among other offenses. He is highly respected within the Justice Department and the criminal tax bar and brings a new breadth and depth of experience to our Criminal Tax practice," said Patricia Sweeney, Chair of Miller & Chevalier's Tax Department.

Over the past few years, a number of factors have contributed to the Internal Revenue Service's (IRS) increasingly aggressive pursuit of criminal tax issues. Most recently, this has been driven by the IRS focus on high-profile enforcement actions to induce compliance and an ever-intensifying spotlight on offshore tax havens and tax-minimization strategies. There has also been a marked rise in DOJ funding to prosecute financial crimes, mounting Congressional scrutiny of cases arising out of financial fraud, and an enhanced and organized focus on bringing high-profile criminal prosecutions.

"Tom is an extremely talented lawyer who is uniquely positioned, because of his significant government and private practice experience, to provide valuable guidance to clients involved in sensitive government investigations and offer skilled trial defense of criminal tax matters," said George Clarke, a Member of the firm's Tax and White Collar practices. "He has conducted complicated investigations of large public companies on both the government and defense side and has defended numerous clients facing criminal tax exposure with respect to tax advantaged transactions, undisclosed foreign financial accounts and income, and other matters."

Renowned Tax and Litigation Practices

Miller & Chevalier's Criminal Tax group possesses the two crucial requirements for effective defense counsel in criminal tax matters: deep technical tax capabilities across a broad spectrum of complex issues and a cutting-edge white collar defense practice with extraordinary jury trial experience. The practice also provides the added dimension of having represented clients before Congressional committees, which is of great value in the current environment. Because criminal tax matters often involve highly complex financial issues, clients benefit from the in-depth substantive knowledge of the firm's tax lawyers in areas such as financial products, partnerships, corporations, cross-border transactions, and tax-exempt organizations.

Miller & Chevalier is widely recognized as a leader in tax matters, with one of the nation's most impressive records of successfully resolving complex tax issues for clients around the globe. The firm's lawyers have achieved extraordinary outcomes for clients in every phase of the IRS administrative process and have litigated more than 100 tax cases in the United States Tax Court, the United States Court of Federal Claims, the Federal District Courts, the Courts of Appeal, and the United States Supreme Court, including several of the largest tax cases of record. Miller & Chevalier tax lawyers include former government officials at the highest levels of the IRS.

This deep and diverse tax experience is coupled with proven white collar criminal defense capabilities. Miller & Chevalier's White Collar lawyers have collectively tried more than 300 criminal cases in state and federal jurisdictions around the country, obtaining high profile acquittals and favorable results in criminal tax cases and other allegations of complex financial fraud. The team has successfully advised and represented corporations and individuals at every stage of criminal litigation, from voluntary disclosure through investigations, indictment, trial, and appeals in proceedings before the IRS, grand juries, the DOJ, and federal and state courts.

"I am very pleased to be joining Miller & Chevalier, which provides an ideal platform for my practice because of the firm's outstanding reputation in the tax and white collar areas," said Zehnle. "In light of the continuing IRS focus on enforcement, including its increased scrutiny of foreign sources of income and failed voluntary disclosures, the recently enacted Foreign Account Tax Compliance Act and Global High Wealth Industry Initiative, and the Service's reinvigorated whistleblower program, we are likely to see an increase in criminal tax investigations and prosecutions for individuals and corporations. Miller & Chevalier's deep experience in the criminal tax, white collar and government investigations areas will be of great benefit to clients."

About Thomas Zehnle

Zehnle joined the DOJ in 1990, first serving as a federal prosecutor, later as Counsel to the Assistant Attorney General responsible for the Tax Division, and in 2001, as Chief of the Tax Division's Criminal Enforcement Section (Southern). He conducted extensive grand jury investigations and prosecuted complex financial fraud cases involving tax evasion, money laundering, conspiracy, false claims and Bank Secrecy Act violations. As Chief of the Section, Zehnle was responsible for supervising all major aspects of criminal tax investigations and prosecutions across a wide swath of the country, including the development and implementation of trial strategies and tactics needed for complex white collar cases.

Although he has particular experience in the area of criminal tax, Zehnle's practice also includes conducting and managing complicated investigations of large public companies. He has been selected and approved as an outside monitor by regulators, personally handling wide-ranging examinations mandated by the DOJ, the Securities and Exchange Commission, and various state enforcement agencies.

Zehnle served as Co-Chair of the American Bar Association Criminal Justice Section's Tax Enforcement Subcommittee from 2004-2010. He was the recipient of the DOJ's Outstanding Attorney Award in 1994 and 1998, and received DOJ management awards from 2002-2004. He was also the recipient of IRS Honorary Awards in 1995 and 2000.

A frequent author and lecturer, Zehnle earned an A.B., with honors, from the University of Missouri-Columbia and a J.D. from the Marshall-Wythe Law School, College of William and Mary.

About Miller & Chevalier

Founded in 1920, Miller & Chevalier is a Washington, D.C. law firm with a global perspective and leading practices in tax; employee benefits, including ERISA; international law and business; complex litigation; and government affairs. For more information on the firm, visit


Patricia Sweeney, Chair, Tax Department, Miller & Chevalier, 202-626-5926
George Clarke
Thomas Zehnle, Member, Miller & Chevalier Tax and White Collar Departments, 202-626-6062
Laura Miller, Media Relations, Greentarget, 312-252-4104

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