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Michelle F. Schwerin

Shareholder

“It is always quietly thrilling to find yourself looking at a world you know well but have never seen from such an angle before.” – Bill Bryson

Areas of Concentration

  • IRS Audits and Appeals
  • Tax Court Litigation
  • Voluntary Disclosures of Tax Positions and Unfiled Returns
  • Tax Preparer Penalty Investigations and Litigation
  • Criminal Tax Matters
  • White Collar Criminal Defense 
  • Securities and Trading Investigations and Litigation
  • Internal Investigations

Experience at Work

An attorney-CPA, Michelle’s credentials and experience allow her to navigate the intricate world of civil tax examinations, appeals, and litigation, as well as criminal tax investigations and defense. Michelle represents individuals and businesses in a variety of tax matters, including tax liability disputes, innocent spouse claims, claims for penalty abatement, refund claims and litigation, preparer and promoter penalty investigations and tax collection matters.

She also represents clients in all stages of federal and state securities investigations and litigation. She guides individual and business clients who come under investigation by the Securities Exchange Commission for issues such as public reporting, disclosures and insider trading.

In the Community

Michelle is an adjunct professor at Webster University, where she teaches in the Masters of Forensic Accounting program at the Walker School of Business & Technology. Outside of work, Michelle is an active member of the Washington University Alumni Association, participates on the Camper Life Subcommittee for Camp Sabra, and sits on the board of the Henry and Gladys Crown Center for Senior Living.

Memberships & Associations

  • Bar Association of Metropolitan St. Louis
    • Chair of Professional Ethics & Methods of Practice Committee, 2016-2017
    • Member, Finance Committee, present
  • American Bar Association, Section of Taxation
    • Co-Chair of Subcommittee on Important Civil Developments, Criminal and Civil Penalties Committee, present
    • Chair of the Membership Subcommittee of the Criminal and Civil Penalties Committee, 2014 – 2016
  • Missouri Society of CPA’s
    • Young Professionals Committee
    • Professional Learning and
      Networking Task Force
  • Women’s White Collar Defense Association
    • Founding Member, St. Louis Chapter
  • Missouri Bar
  • Digital Currency and Ledger Defense Coalition (DCLDC)

Awards & Designations

Publications

  • “When Failing to Pay Taxes Becomes a Federal Crime”, St. Louis Bar Journal, Fall 2018
  • “Invest in Your Personal Brand”, The Asset, March/April 2017
  • Its Bark is Worse than its Bit(e): Regulatory and Criminal Law Implications of Virtual Currency”, Criminal Justice, Winter 2017
  • “The High Stakes of Payroll Tax Fraud,” St. Louis Bar Journal, Winter 2016
  • “Identity Theft and Income Tax Returns: What do you mean I’ve already filed my return?” St. Louis Lawyer Magazine, May 2014
  • “The Swiss and Foreign Account Controversy and International Tax Fraud in the 21st Century,” St. Louis Bar Journal, Summer 2013

Presentations

  • The IRS’s Modern Use of Artificial Intelligence and Big Data in Tax Enforcement” American Bar Association (ABA) Webinar, December 2018
  • “Eliminating Roadblocks” American Society of Tax Problem Solvers’ Annual Taxpayer Representation Super Conference, Las Vegas, NV, October 2018
  • Reports of Subcommittees on Important Developments – Civil & Criminal Tax Penalties“, 2018 American Bar Association Tax Section Joint Fall Meeting, Atlanta, GA, September 2018
  • The IRS’s Modern Use of Artificial Intelligence and Big Data in Tax Enforcement”, 2018 American Bar Association Tax Section Joint Fall Meeting, Atlanta, GA, September 2018
  • Legal Implications of Blockchain Systems Adoption”, Midwest Accounting and Finance Blockchain Conference, Missouri Society of CPAs, September 2018
  • Representing Taxpayers Before IRS Appeals with respect to Penalties Resulting from the Failure to Report Foreign Income or Assets”, Agostino & Associates Annual International Tax Enforcement Update, Hackensack, NJ, June 2018
  • “Succession Planning: Attracting, Retaining, and Utilizing Young Professional Talent”, Missouri Society of Certified Public Accountants (MOCPA) Annual Members Convention, Lake Ozarks, MO, June 2018
  • Hot Topics in Tax Fraud”, Institute of Internal Auditors & Association of Certified Fraud Examiners, St. Louis Chapter, 8th Annual Multi-Track Conference, St. Louis, MO, March 2018
  • Reports of Subcommittees on Important Developments – Civil & Criminal Tax Penalties“, 2018 American Bar Association Tax Midyear Meeting, San Diego, CA, Feb. 2018
  • Professional Development for Busy Women: The Cliffnotes!”, Missouri Society of Certified Public Accountants, St. Louis, MO, Feb. 2018
  • “To Cooperate or Not to Cooperate, That is the Question”, Federal Bar Association, St. Louis Chapter, St. Louis, MO, Oct. 2017
  • “Employment Tax Enforcement by the Department of Justice and Internal Revenue Service in 2017”, Bar Association of Metropolitan St. Louis, St. Louis, MO, Oct. 2017
  • Sentencing in Tax Prosecutions: The Latest Developments and Most Important Considerations”, 2017 American Bar Association Joint Fall CLE Meeting, Austin, TX, Sept. 2017
  • Savvy Ways to Locate Hidden Assets, Interests and Income (with Real-World Examples)”, National Business Institute, September 2016
  • “Practical Considerations for Taxpayer Representation in Criminal Tax Investigations”, ISBA Federal Tax Conference, Chicago, IL, Feb. 2016
  • “When the Accountant is a Witness: Ethical and Other Considerations”, ABA’s 32nd Annual National Institute on Criminal Tax Fraud and the Fifth Annual National Institute on Tax Controversy, Las Vegas, NV, Dec. 2015
  • “Effective Representation During An Eggshell Audit—Avoiding a Criminal Referral and Civil Fraud Penalty”, Illinois State Bar Association’s Federal Tax Conference, Chicago, IL, Feb. 2015
  • “Ethical Considerations in Tax Controversy”, Tulane Tax Institute, New Orleans, LA, Oct. 2014
  • “What is Civil Law and What is Criminal Law?”, Missouri Bar, Mini Law School for the Public, St. Louis, MO, Oct. 2014
  • “Statutes of Limitations in International Civil and Criminal Tax Matters: The Rules and Many Exceptions”, American Bar Association, Section of Taxation, Fall Meeting, Denver, CO, Sept. 2014
  •  Participant, “Criminal Tax Workshop: The Basics”, ABA 30th Annual National Institute on Criminal Tax Fraud and 3rd 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, St. Louis, MO, 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, Branson, MO, Aug. 2013

Licensed to Practice

  • Missouri
  • Illinois
  • U.S. District Court, Eastern District of Missouri
  • U.S. Tax Court
  • Certified Public Accountant

Education

  • J.D., Washington University, with honors (2010)
  • B.S.M. Finance and Accounting, Tulane University, with honors (2006)
Schwerin to Present at 2018 ABA National Institute on Criminal Tax Fraud and Tax Controversy
Schwerin Presented on IRS’s Data Analytics Program at 2018 ABA Webinar Panel
Capes Sokol Announces Schwerin as New Shareholder