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Barclay Taylor
Partner
201 17th Street NW
Suite 1700
Atlanta, GA 30363
Barclay is a tenured tax attorney with more than a decade of experience, particularly in tax controversy. He represents individuals, businesses, trusts, and estates in all stages of disputes with the IRS and state taxing authorities. Additionally, he regularly represents taxpayers in examinations, appeals, and litigation before the United States Tax Court, Federal District Courts, and...
Barclay is a tenured tax attorney with more than a decade of experience, particularly in tax controversy. He represents individuals, businesses, trusts, and estates in all stages of disputes with the IRS and state taxing authorities. Additionally, he regularly represents taxpayers in examinations, appeals, and litigation before the United States Tax Court, Federal District Courts, and the U.S. Court of Federal Claims.
He assists clients with numerous issues including penalty disputes, lien disputes, tax collection resolutions, refund claims, employment tax issues, worker classification issues, reasonable compensation disputes, foreign asset reporting, voluntary disclosures, conservation easement disputes, Qualified Opportunity Zone Funds, Employee Retention Credits (ERC), Paycheck Protection Program (PPP), and more.
the U.S. Court of Federal Claims.
He assists clients with numerous issues including penalty disputes, lien disputes, tax collection resolutions, refund claims, employment tax issues, worker classification issues, reasonable compensation disputes, foreign asset reporting, voluntary disclosures, conservation easement disputes, Qualified Opportunity Zone Funds, Employee Retention Credits (ERC), Paycheck Protection Program (PPP), and more.
Experience
Previous Professional Experience
- Of Counsel, Chair of Tax Controversy Practice, AM Law 200 Law Firm (2023–2025)
- Senior Counsel, AM Law 200 Law Firm (2014–2023)
- Associate, International Tax, “Big Four” Accounting Firm (2011-2014)
Representative Matters
- Successfully settled audit of corporate business expenses including bad debt, depreciation, and aircraft deductions.
- Successfully settled reasonable compensation audit of corporate officer resulting in no changes for the taxpayer.
- Successfully settled worker classification audit saving the taxpayer over $100,000 in employment tax liabilities.
- Obtained full relief for taxpayer in trust fund recovery penalty (TFRP) action related to employment taxes.
- Successfully settled audit of a multimillion-dollar estate resulting in no additional tax liability for the taxpayer.
- Negotiated installment agreement for taxpayer with over $2 million tax liability.
- Successfully settled $1 million transfer pricing dispute resulting in no additional tax liability for the taxpayer.
- Successfully settled foreign information return and FBAR penalties of $1.7 million for less than $400,000.
- Successfully obtained penalty relief for multiple individuals in the Offshore Voluntary Disclosure Program (OVDP) and Streamline Disclosure Programs.
- Represented multiple conservation easement donors at IRS Exam, IRS Appeals, and the United States Tax Court.
- Obtained multiple favorable private letter rulings (PLRs) for late S-Corporation elections.
Education
- Southern Methodist University, LLM, Taxation (2011)
- Mercer University School of Law, JD (2010)
- University of Georgia, BA (2006)
Admissions
- Georgia
- U.S. Tax Court
- U.S. Court of Federal Claims
- U.S. District Court for the Northern District of Georgia
- Georgia State Courts
- Georgia Court of Appeals
- Georgia Supreme Court
Clerkships
- the Honorable Anne Elizabeth Barnes, Georgia Court of Appeals (2009)
Practice Areas
Previous Professional Experience
- Of Counsel, Chair of Tax Controversy Practice, AM Law 200 Law Firm (2023–2025)
- Senior Counsel, AM Law 200 Law Firm (2014–2023)
- Associate, International Tax, “Big Four” Accounting Firm (2011-2014)
Representative Matters
- Successfully settled audit of corporate business expenses including bad debt, depreciation, and aircraft deductions.
- Successfully settled reasonable compensation audit of corporate officer resulting in no changes for the taxpayer.
- Successfully settled worker classification audit saving the taxpayer over $100,000 in employment tax liabilities.
- Obtained full relief for taxpayer in trust fund recovery penalty (TFRP) action related to employment taxes.
- Successfully settled audit of a multimillion-dollar estate resulting in no additional tax liability for the taxpayer.
- Negotiated installment agreement for taxpayer with over $2 million tax liability.
- Successfully settled $1 million transfer pricing dispute resulting in no additional tax liability for the taxpayer.
- Successfully settled foreign information return and FBAR penalties of $1.7 million for less than $400,000.
- Successfully obtained penalty relief for multiple individuals in the Offshore Voluntary Disclosure Program (OVDP) and Streamline Disclosure Programs.
- Represented multiple conservation easement donors at IRS Exam, IRS Appeals, and the United States Tax Court.
- Obtained multiple favorable private letter rulings (PLRs) for late S-Corporation elections.
Media
Recognitions
- Best Lawyers®: Ones to Watch, Tax Law (2022-2025)
- Georgia Trend's Legal Elite (2023-2024)
- Georgia Super Lawyers, Rising Star (2020-2022)
Professional Activities
- American Bar Association, Tax Section
- Georgia Bar Association, Tax Section and Corporate Section
- Atlanta Bar Association, Tax Section
- International Fiscal Association
- Atlanta Film Festival, Board of Directors (2013-2019)
Community
- Peachtree Presbyterian Church, Basketball Coach (2023-2025)
- Buckhead Baseball, Volunteer (2024-2025)
Barclay is a tenured tax attorney with more than a decade of experience, particularly in tax controversy. He represents individuals, businesses, trusts, and estates in all stages of disputes with the IRS and state taxing authorities. Additionally, he regularly represents taxpayers in examinations, appeals, and litigation before the United States Tax Court, Federal District Courts, and... the U.S. Court of Federal Claims.
He assists clients with numerous issues including penalty disputes, lien disputes, tax collection resolutions, refund claims, employment tax issues, worker classification issues, reasonable compensation disputes, foreign asset reporting, voluntary disclosures, conservation easement disputes, Qualified Opportunity Zone Funds, Employee Retention Credits (ERC), Paycheck Protection Program (PPP), and more.
Experience
The following is a selected sampling of matters and is provided for informational purposes only. Past success does not indicate the likelihood of success in any future matter.Previous Professional Experience
- Of Counsel, Chair of Tax Controversy Practice, AM Law 200 Law Firm (2023–2025)
- Senior Counsel, AM Law 200 Law Firm (2014–2023)
- Associate, International Tax, “Big Four” Accounting Firm (2011-2014)
Representative Matters
- Successfully settled audit of corporate business expenses including bad debt, depreciation, and aircraft deductions.
- Successfully settled reasonable compensation audit of corporate officer resulting in no changes for the taxpayer.
- Successfully settled worker classification audit saving the taxpayer over $100,000 in employment tax liabilities.
- Obtained full relief for taxpayer in trust fund recovery penalty (TFRP) action related to employment taxes.
- Successfully settled audit of a multimillion-dollar estate resulting in no additional tax liability for the taxpayer.
- Negotiated installment agreement for taxpayer with over $2 million tax liability.
- Successfully settled $1 million transfer pricing dispute resulting in no additional tax liability for the taxpayer.
- Successfully settled foreign information return and FBAR penalties of $1.7 million for less than $400,000.
- Successfully obtained penalty relief for multiple individuals in the Offshore Voluntary Disclosure Program (OVDP) and Streamline Disclosure Programs.
- Represented multiple conservation easement donors at IRS Exam, IRS Appeals, and the United States Tax Court.
- Obtained multiple favorable private letter rulings (PLRs) for late S-Corporation elections.
Education
- Southern Methodist University, LLM, Taxation (2011)
- Mercer University School of Law, JD (2010)
- University of Georgia, BA (2006)
Admissions
- Georgia
- U.S. Tax Court
- U.S. Court of Federal Claims
- U.S. District Court for the Northern District of Georgia
- Georgia State Courts
- Georgia Court of Appeals
- Georgia Supreme Court
Clerkships
- The Honorable Anne Elizabeth Barnes, Georgia Court of Appeals (2009)
Practice Areas
- Best Lawyers®: Ones to Watch, Tax Law (2022-2025)
- Georgia Trend's Legal Elite (2023-2024)
- Georgia Super Lawyers, Rising Star (2020-2022)
- American Bar Association, Tax Section
- Georgia Bar Association, Tax Section and Corporate Section
- Atlanta Bar Association, Tax Section
- International Fiscal Association
- Atlanta Film Festival, Board of Directors (2013-2019)
- Peachtree Presbyterian Church, Basketball Coach (2023-2025)
- Buckhead Baseball, Volunteer (2024-2025)
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