Moore Tax Law Group Press Release

Moore Tax Law Group LLC is pleased to announce Kathy Enstrom, former Executive within Internal Revenue Service Criminal Investigation (IRS CI), has joined the firm as Director of Investigations.

Ms. Enstrom departed IRS CI in July 2021 after 26 years of service at the agency. Her last IRS assignment was Executive Director of Field Operations-Northern Area overseeing one-third of the United States which included offices headquartered in Chicago, Detroit, Cincinnati, Philadelphia, Newark, Boston and New York City. Ms. Enstrom will operate out of Moore Tax Law Group’s Chicago office.

Ms. Enstrom brings over a quarter of a century’s experience investigating financial crimes across multiple law enforcement agencies. Her extensive network within the government and private sector will be invaluable to Moore Tax Law Group’s client base of individuals and businesses. Ms. Enstrom will assist clients facing governmental investigations involving all manner of alleged financial and economic crimes, including tax crimes, money laundering, and other related financial violations.

“I’ve always had the upmost respect for Kathy as an IRS Executive and the Special Agent in Charge of the criminal investigations our office defended,” said managing member Guinevere Moore. “She’s thorough, tough, and trustworthy. She was always a fair and formidable adversary, and I can’t think of a better addition to our team. Having investigated tax evasion, money laundering, and other financial crimes – especially PPP and EDIL loan fraud – from inside two government agencies, Kathy is well positioned to help Moore Tax Law Group’s clients achieve the best possible results.”

“I have known Guinevere Moore and her law firm for a number of years and have admired her passion for tax controversy law and determination to ensure Moore Tax Law Group clients receive the best legal advice,” said Ms. Enstrom. “I am very pleased to join the firm to provide my experience and expertise in assisting clients with their tax challenges toward a strategic resolution.”

“After many years of budget cuts, the IRS will finally be well-resourced, getting an influx of $80 billion in funding,” according to Moore. “That money will go towards improving IRS technology and increasing audits on the wealthiest Americans. Adding Enstrom to the Moore Tax Law Group team will ensure that we are well positioned to assist those who are on the receiving end of the next IRS enforcement push.”

During her career, Ms. Enstrom oversaw investigations nationwide into some of the most significant financial crimes investigated involving tax evasion, money laundering, bribery, international corruption, bank fraud, cyber and cryptocurrency crimes, and terrorist financing.

Ms. Enstrom began her IRS career in 1995 as an IRS CI intern in Cedar Rapids, Iowa, and the year following was sworn in as a Special Agent in Chicago, Illinois. She then moved throughout the organization in various investigative and management roles. These supervisory roles were located in Chicago, New York City, Washington DC, Los Angeles, Milwaukee, Cincinnati, and Ottawa, Canada.

Her first executive assignment within IRS CI was overseeing CI’s Operations, Policy and Support. There she oversaw all CI policy and Internal Revenue Manual updates. Responsibilities included leading the Financial Crimes Section, National Forensic Lab, Special Investigative Techniques Section, Warrants & Forfeitures Section, Treasury Liaison, TEOAF Liaison and FinCEN Liaison.

Ms Enstrom’s IRS Executive career also included being the Deputy Chief of Staff to former IRS Commissioner Charles Rettig and the Executive Special Agent in Charge for the Chicago Field Office.

Ms. Enstrom’s time in federal law enforcement concluded with her role as Chicago’s Special Agent in Charge of Federal Deposit Insurance Corporation (FDIC), Office of Inspector General from July 2021 to March 2023. In this role, she conducting investigations involving bank fraud and oversaw agents covering 6 states in the Midwest including Illinois, Wisconsin, Indiana, Michigan, Ohio and Kentucky.

Ms. Enstrom has a Bachelor of Business Administration in Accounting from Mount Mercy University (Cedar Rapids, IA) and a Master of Business Administration from Cardinal Stritch University (Milwaukee, WI).

About Moore Tax Law Group

Moore Tax Law Group is a leading tax controversy and tax litigation boutique, representing United States taxpayers from all over the world in high-stakes criminal and civil disputes with the United States. The firm represents clients at all stages of disputes, from an IRS criminal or civil exam to the United States Supreme Court. We are creative and zealous advocates who are deeply committed to defending taxpayers and accomplishing the best possible results. The team’s unique approach to client counseling helps ensure that clients who are facing a dispute with the United States know what to expect and are equipped with the tools to handle it.

Chicago, Illinois (February 28, 2023) In a 5-4 opinion delivered by Justice Gorsuch, the Supreme Court held in Bittner v. United States, 598 U.S. ___ (2023) that taxpayers who make non-willful errors or omissions on their Report of Foreign Bank Accounts, or FBARs, will only face one penalty per form, regardless of the number of accounts for which the taxpayer made a non-willful error.  The Supreme Court’s holding ensures that taxpayers who fail to comply with the Bank Secrecy Act’s FBAR requirements and do not do so willfully will have a maximum penalty of $10,000 per form, not $10,000 per account.

Moore Tax Law Group, LLC was proud to represent the Center for Taxpayer Rights, which joined the American College of Tax Counsel as amicus curie in Bittner.  “Taxpayer rights are fundamental to a system based upon voluntary compliance,” says Elizabeth J. Atkinson, a partner with Whiteford, Taylor, Preston LLP and a member of the Board of Directors for the Center for Taxpayer Rights.  “When penalties are applied harshly, the effect is to lower overall compliance and to create distrust.  See  the TAS research study, especially footnote 20.”  Speaking on behalf of the Center, Atkinson added that the Center is gratified that the Court upheld “the Due Process Clause’s promise of  ‘a fair warning should be given to the world in language the common world would understand…’”

“I was honored to represent the Center for Taxpayer Rights in this case and help advance the cause on behalf of taxpayers,” says Guinevere Moore, lead counsel for the Center and managing member of Moore Tax Law Group.  “We thought long and hard about what arguments to advance that would demonstrate to the Court just how dire the impact of the government’s interpretation of the FBAR law was, especially for low-income and immigrant taxpayers.  Having the Court cite to our brief and expressly find that the Rule of Lenity required this result was a highlight of my professional career,”  Moore added.  The Rule of Lenity is a long-standing principle of statutory construction that requires statutes imposing penalties against individuals to be strictly construed against the government.

“As an immigrant myself, I am personally aware of the difficulties that immigrant communities face in matters of tax compliance,” explained Zhanna Ziering, co-counsel for the Center for Taxpayer Rights and partner in Moore Tax Law Group.  “Complexities of the U.S. tax reporting obligations combined with language barrier, lack of tax education during the integration process, and reliance on tax return prepares servicing the community can easily result in innocent reporting missteps.  The Court’s decision ensures that the penalties for these mistakes will be commensurate with the violation, and not disproportionally sanction individuals solely based on the number of accounts they maintained.”  Ms. Ziering is a nationally recognized FBAR expert and is the co-author of Bloomberg’s BNA Tax Management Portfolio, Report of Foreign Bank and Financial Accounts. “The government has had a long and overwhelming record of victories in FBAR enforcement and began taking an overly-aggressive and unfair approach to administering the FBAR penalties.  We hope this is the first step in curtailing penalties that are not necessary to fairly administer our tax laws,” Ziering added.

About Moore Tax Law Group, LLC

Moore Tax Law Group is a leading tax controversy and tax litigation boutique, representing United States taxpayers from all over the world in high-stakes criminal and civil disputes with the United States.  The firm represents clients at all stages of disputes, from an IRS criminal or civil exam to the United States Supreme Court.  We are creative and zealous advocates who are deeply committed to defending taxpayers and accomplishing the best possible results.  The team’s unique approach to client counseling helps ensure that clients who are facing a dispute with the United States know what to expect and are equipped with the tools to handle it.