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Michelle F. Schwerin

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“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 serves as the vice chair of the Board of Police Commissioners for the St. Louis County Police Department. She is an adjunct professor of law in Washington University Law School’s Tax LL.M. program. Michelle is also active in the Saint Louis Community through her board positions at the Henry and Gladys Crown Center for Senior Living and St. Louis Jewish Community Center.

Awards & Recognitions

Awards

  • Missouri Lawyers Weekly, The POWER List – Tax (2021 & 2022)
  • The St. Louis Jewish Community Center, J Associates Emerging Leader Award (2021)
  • Super Lawyers® | Missouri and Kansas Rising Stars List, Rising Star (2018 – Present)
  • The Best Lawyers in America® | Litigation and Controversy – Tax, St. Louis (2017 – Present)
  • Missouri Society of Certified Public Accountants, Outstanding Young Professional (2017)
  • Bar Association of Metropolitan St. Louis, John C. Shepherd Professional Awardee (2016 – 2017)

Appointments

  • St. Louis County Police Department – Board of Police Commissioners | Vice Chair (2019 – Present)

Recognitions

  • American Bar Association – Section of Taxation | Class of Nolan, Fellow (2014 – 2015)
  • Missouri Bar Leadership Academy, Member (2013 – 2014)
  • Digital Currency and Ledger Defense Coalition, Inaugural Member

Knowledge & Insights

Speaking Engagements

  • The Ethics Surrounding Frequently Asked Questions, Standards of Tax Practice Committee. May Tax Meeting. American Bar Association | Tax Section. Virtual. (2022)
  • Collection Due Process Cases in U.S. Tax Court and Related Issues – Court Procedure & Practice Committee. May Tax Meeting. American Bar Association | Tax Section. Virtual. (2022)
  • Enforcement & Criminal – Hot Topics: IRS Enterprise Compliance Initiatives. Tax Law Conference. Federal Bar Association. Virtual. (2022)
  • Criminal Tax Workshop. National Institute on Criminal Tax Fraud and the National Institute on Tax Controversy. American Bar Association | Tax Section & Criminal Justice Section. Las Vegas, NV. (2021)
  • All Too Common: A Fraud Investigation Case Study. Fraud & Forensic Accounting Conference. Missouri Society of Certified Public Accountants. St. Louis, MO. (2021)
  • I Certified What?!?: Evaluating Taxpayers’ Exposure From their Participation in CARES and ARA Programs. Joint Fall Tax Meeting. American Bar Association | Tax Section & Real Property, Trust and Estate Law Section. Virtual. (2021)
  • Financial Misconduct: Hidden Assets, Fraudulent Transfers, Tax Evasion and More. National Business Institute. Webinar. (2021)
  • IRS Fraud Enforcement and Cryptocurrency Update – Tax Practice Management Committee. May Tax Meeting. American Bar Association | Tax Section. Virtual. (2021)
  • Important Civil Developments – Civil and Criminal Tax Penalties Committee. Joint Fall Tax Meeting. American Bar Association | Tax Section & Real Property, Trust and Estate Law Section. Virtual. (2020)
  • “My Spouse Did What?!?”: Avoiding Ethical Pitfalls When Representing Spouses. American Society of Tax Problem Solvers. (2020)
  • When You Need to Disclose More Than Just a Tax Crime. May Tax Meeting. American Bar Association | Tax Section. Virtual. (2020)
  • Criminal Tax Workshop. National Institute on Criminal Tax Fraud and the National Institute on Tax Controversy. American Bar Association | Tax Section & Criminal Justice Section. Las Vegas, NV. (2019)
  • The Reasonable Cause Defense: Effective Strategies When Requesting Penalty Abatement. Joint Fall Tax Meeting. American Bar Association | Tax Section & Real Property, Trust and Estate Law Section. San Francisco, CA. (2019)
  • It’s a Brave New World: Ethical Issues in the Information Age. Joint Fall Tax Meeting. American Bar Association | Tax Section & Real Property, Trust and Estate Law Section. San Francisco, CA. (2019)
  • Legal Considerations for Blockchain Implementation and Use. Midwest Accounting & Finance Blockchain Conference. St. Louis, MO. (2019)
  • Litigating International Penalties in Collection”, American Bar Association, Section of Taxation, May Meeting, Washington D.C., May 2019
  • Important Civil DevelopmentsCivil and Criminal Tax Penalties Committee. May Tax Meeting. American Bar Association | Tax Section. Washington D.C. (2019)
  • It Doesn’t End with Upjohn: Preserving Privilege and Other Ethical Considerations in Internal Investigations. White Collar Crime Seminar. Bar Association of Metropolitan St. Louis and Federal Bar Association. St. Louis, MO. (2019)
  • Employment Tax: Your Client’s Legal Obligations and the Risks of Noncompliance. Missouri Bar. Virtual. (2019)
  • Tax Consequences of Employment Litigation. National Employment Lawyers Association | St. Louis Chapter. St. Louis, MO. (2019)
  • Criminal Prosecution of Employment Tax Cases. National Institute on Criminal Tax Fraud and the National Institute on Tax Controversy. American Bar Association | Tax Section & Criminal Justice Section. Las Vegas, NV. (2019)
  • The IRS’s Modern Use of Artificial Intelligence and Big Data in Tax Enforcement. American Bar Association. Virtual. (2018)
  • Eliminating Roadblocks. Taxpayer Representation Super Conference. American Society of Tax Problem Solvers. Las Vegas, NV. (2018)
  • Women in Leadership Conference. Missouri Society of Certified Public Accountants | St. Louis Chapter. St. Louis, MO. (2018)
  • Important Civil DevelopmentsCivil and Criminal Tax Penalties Committee. Joint Fall Tax Meeting. American Bar Association | Tax Section & Real Property, Trust and Estate Law Section. Atlanta, GA. (2018)
  • The IRS’s Modern Use of Artificial Intelligence and Big Data in Tax Enforcement. Joint Fall Tax Meeting. American Bar Association | Tax Section & Real Property, Trust and Estate Law Section. Atlanta, GA. (2018)
  • Legal Implications of Blockchain Systems Adoption. Midwest Accounting and Finance Blockchain Conference. Missouri Society of Certified Public Accountants | St. Louis Chapter. St. Louis, MO. (2018)
  • Representing Taxpayers Before IRS Appeals with respect to Penalties Resulting from the Failure to Report Foreign Income or Assets. International Tax Enforcement Update. Hackensack, NJ. (2018)
  • Succession Planning: Attracting, Retaining, and Utilizing Young Professional Talent. Annual Members Convention. Missouri Society of Certified Public Accountants. Lake Ozarks, MO. (2018)
  • Hot Topics in Tax Fraud. Multi-Track Conference. Institute of Internal Auditors & Association of Certified Fraud Examiners | St. Louis Chapter. St. Louis, MO. (2018)
  • Important Civil DevelopmentsCivil and Criminal Tax Penalties Committee. Midyear Tax Meeting. American Bar Association | Tax Section. San Diego, CA. (2018)
  • Professional Development for Busy Women: The Cliffnotes!. Missouri Society of Certified Public Accountants | St. Louis Chapter. St. Louis, MO. (2018)
  • To Cooperate or Not to Cooperate, That is the Question. Federal Bar | St. Louis Chapter. St. Louis, MO. (2017)
  • Employment Tax Enforcement by the Department of Justice and Internal Revenue Service. Bar Association of Metropolitan St. Louis. St. Louis, MO. (2017)
  • Sentencing in Tax Prosecutions: The Latest Developments and Most Important Considerations. Joint Fall Tax Meeting. American Bar Association | Tax Section & Real Property, Trust and Estate Law Section. Austin, TX. (2017)
  • Savvy Ways to Locate Hidden Assets, Interests and Income (with Real-World Examples). National Business Institute. Virtual. (2016)
  • Practical Considerations for Taxpayer Representation in Criminal Tax Investigations. Federal Tax Conference. Illinois State Bar Association. Chicago, IL. (2016)
  • When the Accountant is a Witness: Ethical and Other Considerations. National Institute on Criminal Tax Fraud and the National Institute on Tax Controversy. American Bar Association | Tax Section & Criminal Justice Section. Las Vegas, NV. (2015)
  • Effective Representation During an Eggshell Audit–Avoiding A Criminal Referral and Civil Fraud Penalty. Federal Tax Conference. Illinois State Bar Association. Chicago, IL. (2015)
  • Ethical Considerations in Tax Controversy. Tulane Tax Institute. New Orleans, LA. (2014)
  • What is Civil Law and What is Criminal Law? Mini Law School for the Public. Missouri Bar. St. Louis, MO. (2014)
  • Statutes of Limitations in International Civil and Criminal Tax Matters: The Rules and Many Exceptions. Joint Fall Tax Meeting. American Bar Association | Tax Section & Real Property, Trust and Estate Law Section. Denver, CO. (2014)
  • Criminal Tax Workshop: The Basics. National Institute on Criminal Tax Fraud and the National Institute on Tax Controversy. American Bar Association | Tax Section & Criminal Justice Section. Las Vegas, NV. (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 Chapter. St. Louis, MO. (2013)
  • “My ‘Soon-to-be Ex’ is a Tax Cheat!”: Effectively Representing the ‘Innocent Spouse’ During Divorce Proceedings. Family Law Conference. Missouri Bar. Branson, MO. (2013)

Publications

  • “The New Voluntary Disclosure Procedures: Weighing the High Cost to Avoid Risk of Prosecution.” The Asset. (2019)
  • “When Failing to Pay Taxes Becomes a Federal Crime.” St. Louis Bar Journal. (2018)
  • “Invest in Your Personal Brand.” The Asset. (2017)
  • Its Bark is Worse than its Bit(e): Regulatory and Criminal Law Implications of Virtual Currency.” Criminal Justice. (2017)
  • “The High Stakes of Payroll Tax Fraud.” St. Louis Bar Journal. (2016)
  • “Identity Theft and Income Tax Returns: What do you mean I’ve already filed my return?” St. Louis Lawyer Magazine. (2014)
  • “The Swiss and Foreign Account Controversy and International Tax Fraud in the 21st Century.” St. Louis Bar Journal. (2013)

Teaching

  • Accounting for Tax Lawyers. Master of Laws (LL.M.) in Taxation Program. Washington University School of Law | Adjunct Professor
  • Legal Procedure, Substantive Law and Professional Ethics in Forensic Accounting. Masters in Forensic Accounting Program. Webster University – Walker School of Business & Technology | Adjunct Professor

Firm Programs

Firm Insights

Admissions & Qualifications

Bar & Court Admissions

  • Missouri
  • Illinois
  • U.S. District Courts
    • Eastern District of Missouri
    • District of Colorado
  • U.S. Tax Court

Additional Credentials

  • Certified Public Accountant – Missouri

Educational Background

  • J.D., Washington University, with honors (2010)
  • B.S.M. Finance and Accounting, Tulane University, with honors (2006)

Leadership & Community Engagement

Current Leadership Positions

  • Women in White Collar Defense Association, St. Louis Chapter | Social Media Coordinator
  • American Bar Association – Taxation Section | Co-Chair, Civil and Criminal Tax Penalties Committee – Subcommittee on Important Criminal Developments (2013 – Present)
  • Henry and Gladys Crown Center for Senior Living | Board Member
  • St. Louis Jewish Community Center | Board Member
  • Bar Association of Metropolitan St. Louis | Member, Finance Committee (2017 – Present)

Past Leadership Positions

  • Missouri Society of CPAs, St. Louis Chapter | Chair (2020 – 2021)
  • Missouri Society of CPAs, St. Louis Chapter | Professional Learning and Networking Task Force
  • American Bar Association – Taxation Section | Co-Chair, Civil and Criminal Tax Penalties Committee – Subcommittee on Important Civil Developments (2017 – 2020)
  • American Bar Association – Taxation Section | Chair, Civil and Criminal Tax Penalties Committee – Membership Subcommittee (2014 – 2016)
  • Bar Association of Metropolitan St. Louis | Chair, Professional Ethics & Methods of Practice Committee (2016 – 2017)

Professional Organizations

  • Bar Association of Metropolitan St. Louis
  • Women in White Collar Defense Association | St. Louis Chapter
  • American Bar Association | Taxation Section
  • Missouri Society of CPAs | St. Louis Chapter
  • Digital Currency and Ledger Defense Coalition
  • Missouri Bar

Civic & Community

  • Henry and Gladys Crown Center for Senior Living
  • St. Louis Jewish Community Center
Three Capes Sokol Attorneys Selected to 2022 POWER List for Tax
Twelve Capes Sokol Attorneys Selected to the 2021 Missouri & Kansas Super Lawyers and Rising Stars Lists
Dove & Schwerin to Present at Fraud & Forensic Accounting Conference