Areas of Concentration
Criminal Tax Defense
IRS Audits and Appeals
Tax Court Litigation
Offshore Account Disclosures
Claims for Innocent Spouse Relief
Tax Preparer Penalty Investigations
Significant Tax Collection Matters
LL.M., Taxation, Washington University (2015)
J.D., University of Missouri-Columbia School of Law (2003)
B.S., with honors, Business Administration, University of Missouri-Columbia (1999)
Designations & Awards
- Best Lawyers’ 2015 St. Louis Litigation and Controversy-Tax “Lawyer of the Year”
- President’s Award (for contributions to the Taxation Section), Bar Association of Metropolitan St. Louis, May 2014
- Missouri Lawyer’s Weekly Up and Coming Law Firm Leader 2014
Sara G. Neill is a shareholder and the chair of the Civil & Criminal Tax Controversy and Litigation practice group.
Ms. Neill regularly defends individuals and businesses under investigation for or charged with tax and other white collar crimes. She represents clients through all stages of criminal tax investigations and litigation and handles sensitive IRS audits and appeals. Ms. Neill frequently advises clients in responding to grand jury subpoenas and IRS summonses.
In addition to tax fraud defense, Ms. Neill handles civil tax controversy and litigation matters, including IRS audits, appeals, litigation before the U.S. Tax Court and U.S. District Courts and significant tax collection cases. Ms. Neill advises and represents clients in voluntary disclosure matters, claims for innocent spouse relief, summons enforcement proceedings, claims for refund, trust fund recovery penalty matters and requests for penalty abatement.
Ms. Neill defends lawyers and accountants in preparer/promoter investigations and appeals, handles injunctive proceedings brought by the U.S. Department of Justice and advises professionals with respect to matters involving the IRS Office of Professional Responsibility. She also represents taxpayers before the Missouri Department of Revenue in income and sales and use tax examinations, as well as appeals before the Administrative Hearing Commission.
Ms. Neill is the Chair of the Taxation Section of the Bar Association of Metropolitan St. Louis and the Co-Chair of the ABA Tax Section’s Civil and Criminal Penalties Committee’s Sub Committee on Important Civil Developments. She serves on the Advisory Board for the University of Missouri—Columbia Tax Law Society and is an active member of the St. Louis Lawyers Association and the St. Louis Women’s Law Association. Ms. Neill is an adjunct professor of law at the University of Missouri-Columbia School of Law, teaching Federal Tax Practice and Procedure. Ms. Neill was a member of the Leadership Clayton Class of 2010. She frequently speaks on issues relating to civil and criminal tax controversy.
Ms. Neill has been admitted to practice in both Missouri and Illinois, as well as before the U.S. District Courts for the Eastern and Western Districts of Missouri, the District Court of Kansas and the U.S. Tax Court. She has also appeared pro hac vice in other courts.
- “My Spouse Hasn’t Been Paying Our Taxes? A Practitioner’s Guide to Representing the Innocent Spouse,” Missouri Bar’s Solo and Small Firm Conference, Branson, Missouri, June 2015
- “Handling Cases With Potential Criminal Issues,” Pro Bono & Tax Clinics Committee, American Bar Association, Section of Taxation, May Meeting, Washington, DC, May 2015
- “Important Developments On Civil Penalties,” Civil and Criminal Tax Penalties Committee, American Bar Association, Section of Taxation, May Meeting, Washington, DC, May 2015
- “Effective Representation During An Eggshell Audit–Avoiding A Criminal Referral and Civil Fraud Penalty,” Illinois State Bar Association Federal Tax Conference, Chicago, IL, Feb. 2015
- “Summons Enforcement–Procedure, Privileges, and Petitions to Quash,” American Bar Association, Section of Taxation Midyear Meeting, Houston, TX, Jan. 2015
- “Ethical Considerations in Tax Controversy,” Tulane Tax Institute, New Orleans, LA, Oct. 2014
- “Important Developments On Civil Penalties,” Civil and Criminal Tax Penalties Committee, American Bar Association, Section of Taxation, Joint Fall CLE Meeting, Denver, CO, Sept. 2014
- “The IRS Collection Process: What You Need to Know to Advise Your Clients,” American Bar Association, Webinar, Aug. 2014
- “Cooked Books: A recipe for representing a client with a potential criminal tax problem,” Missouri Bar’s Solo and Small Firm Conference, Branson, MO, Jun. 2014
- ”My client just dumped a large pile of unopened mail on my desk…from the IRS”: Practical tips for the non-tax lawyer when representing a client with a federal tax problem,” BAMSL Bench and Bar Conference, Lake of the Ozarks, MO, May 2014
- “Nuts & Bolts Series: Trying Cases Before the Tax Court,” American Bar Association, Section of Taxation May Meeting, Washington, D.C., May 2014
- “When Tax Fraud and Trust and Estate Administration Intersect: Avoiding an IRS Criminal Investigation and the Assertion of a Penalty for Civil Fraud,” Bar Association of Metropolitan St. Louis’ Ninth Annual Fiduciary Litigation Seminar, St. Louis, MO, Feb. 2014
- “Important Developments On Civil Penalties,” Civil and Criminal Tax Penalties Committee, American Bar Association, Section of Taxation Midyear Meeting, Phoenix, AZ, Jan. 2014
- “Important Recent Updates in Criminal Tax Fraud and Civil Tax Controversy,” Bar Association of Metropolitan St. Louis January 2014 Tax Update, St. Louis, MO, Jan. 2014
- “Dialing for Dollars: The IRS Collection Process-Administrative and Judicial Solutions,” American Bar Association’s 30th Annual National Institute on Criminal Tax Fraud and the Third Annual National Institute on Tax Controversy, Las Vegas, NV, Dec. 2013
- “Navigating the Ethical Minefield and Keeping Your C.P.A. License! Practical Advice for Avoiding Ethical Concerns in Your Tax Practice and Properly Handling Them When They Arise,” Missouri Society of Certified Public Accountants, Nov. 2013
- “My ‘Soon-to-be Ex’ is a Tax Cheat!: Effectively Representing the ‘Innocent Spouse’ During Divorce Proceedings,” The Missouri Bar’s 13th Annual Family Law Conference, Aug. 2013
- “Administrative Tax Strategies and Techniques in a Recessionary Economy,” American Bar Association’s 29th Annual National Institute on Criminal Tax Fraud and the Second Annual National Institute on Tax Controversy, Las Vegas, NV, Dec. 2012, and American Bar Association, Webinar, May 2013
- “An Ethics Challenge: Identifying and Addressing Conflicts of Interest in Tax Controversies,” American Bar Association, Section of Taxation Midyear Meeting, Orlando, FL, Jan. 2013, and American Bar Association, Webinar, Apr. 2013
- “Vanishing Time Limits for Equitable Relief,” American Bar Association, Section of Taxation Midyear Meeting, Orlando, FL, Jan. 2013
- “When Clients With Tax Problems Cause Problems for You: Ethical Issues in Tax Practice,” Missouri Society of Certified Public Accountants, Nov. 2009; American Society of Women Accountants and St. Louis Society of Women Certified Public Accountants, Jan. 2010
- “Whether the IRS Alleges That Your Client is a Fraudster or Just Plain Negligent, in Tax Court Litigation the Penalties Shouldn’t be an Afterthought,” Journal of Passthrough Entities, Forthcoming Jul. 2015
- “Resisting Enforcement of an IRS Administrative Summons After the Supreme Court’s Recent Ruling in U.S. v. Clarke,” Journal of Passthrough Entities, Nov. 2014
- “Avoiding an IRS Criminal Investigation and Tax Fraud Prosecution: Effectively Representing Your Client in an ‘Eggshell Audit,'” St. Louis Bar Journal, Summer 2013