Christopher S. Rizek is a Member in Caplin & Drysdale's Washington, D.C., office.
Services
Mr. Rizek represents taxpayers in all types of federal civil and criminal tax controversy matters. He guides clients through IRS audits, prepares administrative claims and protests of IRS actions, and litigates tax and tax-related cases in U.S. district and appellate courts, the U.S. Court of Federal Claims, and the U.S. Tax Court. In recent years, he has represented numerous taxpayers, financial entities, and professional firms in connection with IRS examinations of tax shelters and related compliance and professional ethics issues.
Highlights
Mr. Rizek has a unique history of government service before joining the firm. From 1984-1988, he was a Trial Attorney with the U.S. Department of Justice, Tax Division, and he received the Outstanding Attorney Award in 1986. From 1995-1998, Mr. Rizek was an Attorney-Advisor and Associate Tax Legislative Counsel with the U.S. Treasury Department, Office of Tax Legislative Counsel, with substantial responsibilities for legislation and regulatory actions involving taxpayer rights, tax practice and procedure, and tax compliance.
Mr. Rizek combination of practical and policy-level experience in government has given him special insight into the actual application of the tax laws and procedures to taxpayers. This experience has been of great value to many of the firm's clients who are faced with complex tax controversies and litigation.
Mr. Rizek also served as Caplin & Drysdale’s internal General Counsel for eleven years, with responsibilities including compliance, risk management, and professional ethics. His background and familiarity with such issues helps provide both theoretical and practical insights to other tax and professional firms.
Professional Activities
Mr. Rizek is an adjunct professor at Georgetown University Law Center and in the Spring of 2012 he taught the course Tax Practice & Procedure (Administrative) to IRS personnel. He has also been a guest lecturer at other law schools and universities, and is a frequent speaker at conferences on tax procedure and ethics issues. Mr. Rizek is also active in civic organizations in Anne Arundel County, Maryland where he resides, and formerly served as Chairman of the Anne Arundel County Ethics Commission.
Speaking Engagements
Mr. Rizek regularly speaks to tax, legal, and other professionals on a variety of tax issues. He has served in numerous capacities for various bar associations involved in taxation, including the ABA Section of Taxation, the DC Bar Tax Section, and the Section of Taxation of the Federal Bar Association.
Mr. Rizek's speaking engagements also include:
- Speaker, Identifying and Targeting Tax Shelters: Microcaptives, Conservation Easements and Beyond, 2021 AICPA National Tax Conference, November 16, 2021
- Panelist, Ethics: A Deep Dive Into Conflicts and Privilege in the COVID-19 Era, ABA Section of Taxation, 32rd Annual Philadelphia Tax Conference, November 9, 2021
- Panelist, Ethical Considerations when Publicly Advocating for a Client, ABA Section of Taxation, Midyear Meeting, January 29, 2021
- Panelist, Court Procedure & Practice Current Developments, ABA Section of Taxation, Midyear Meeting, January 27, 2021
- Speaker, Ethical Issues Under the BBA Partnership Audit Regime, UNC School of Law, Tax Institute Speaker Series, December 4, 2020
- Speaker, Ethics: A Deep Dive Into Conflicts and Privilege in the COVID-19 Era, ABA Section of Taxation, 31st Annual Virtual Philadelphia Tax Conference, November 12, 2020
- Panelist, Ethics, The George Washington University Law School and IRS, 32nd Annual Institute on Current Issues in International Taxation, December 20, 2019
- Panelist, Ethics: When are You Crossing a Line? Real-Life Ethical Issues in Everyday Tax Practice, NYU 78th Institute on Federal Taxation, October 24, 2019
- Panelist, Rock-Partnership Representative-Hard Place, NYU 11th Annual Tax Controversy Forum, NYU School of Professional Studies, June 20, 2019
- Panelist, Contingency Fees in Tax Cases, ABA Section of Taxation, 2019 ABA Midyear Meeting, January 18, 2019
- Panelist, Ethics, The George Washington University Law School and IRS, 31st Annual Institute on Current Issues in International Taxation, December 14, 2018
- Panelist, Ethics: Keeping Your Communications Confidential, 43rd Annual Insurance Tax Conference, November 9, 2018
- Panelist, Crossing the Line: Real-Life Ethical Issues in Tax Practice, NYU 77th Institute on Federal Taxation, October 25, 2018
- Moderator, ABCs of Summary Accounting Evidence in Tax Court Litigation, 2018 ABA Section of Taxation May Meeting, May 11, 2018
- Panelist, Taxpayer Rights: To What End (Part 1), 2018 ABA Section of Taxation May Meeting, May 11, 2018
- Moderator, Taxpayer Protections in Cross-Border Taxation, 3rd International Conference on Taxpayer Rights, May 3, 2018
- Speaker, A General Counsel's Tales from the Confessional - and Some Tips to Keep You Out of It, 2018 J. Nelson Young Tax Institute, April 27, 2018
- Speaker, Tax Controversy, Portland Tax Forum, April 26, 2018
- Speaker, Defending Positions Taken, Florida ACTEC Fellows Institute, April 20, 2018
- Speaker, Selected Issues in Tax Court, Florida ACTEC Fellows Institute, April 20, 2018
- Panelist, Ethics for Young Tax Lawyers, American Bar Association, 4th Annual Young Tax Lawyers Symposium, April 13, 2018
- Speaker, Christopher Rizek Discusses Ethics at 14th Biennial Parker C. Fielder Oil and Gas Tax Conference, 14th Biennial Parker C. Fielder Oil and Gas Tax Conference, The University of Texas School of Law (Austin), November 17, 2017
- Panelist, Above the Fold: Your Deal, Ethics, Conflicts of Interest and More, Tax Executives Institute 2017 Mergers & Acquisitions / The Lifecycle of a Transaction: An Interdisciplinary Approach, November 7, 2017
- Panelist, How Far Can You Go? Ethical and Penalty Issues In Everyday Tax Practice, NYU 76th Institute on Federal Taxation, October 26, 2017
- Panelist, A Primer on the IRS Disciplinary Process, American Bar Association Section of Taxation 2017 Joint Fall CLE Meeting, September 15, 2017
- Privacy and Transparency, 2nd International Conference on Taxpayer Rights, March 13, 2017
- Speaker, Recent Developments in Appeals, FBA 2017 41st Annual Tax Law Conference, March 3, 2017
- Moderator, Ethical Issues Involving Fees, ABA Tax Section, January 20, 2017
- Panelist, Ethics Panel, GWU-IRS 29th Annual Institute on Current Issues in International Taxation, December 15, 2016
- Speaker, Captive Insurance: New IRS Tax Reporting Regime Potential for Penalties and Examinations, Bloomberg BNA, December 9, 2016
- Speaker, Small Captive Insurers and the New IRS Reporting Regime, Delaware Captive Insurance Association, December 1, 2016
- Panelist, Ethical and Penalty Issues for Tax Practitioners: When Good Tax Planning Turns Bad, NYU 75th Institute on Federal Taxation, October 27, 2016
- Speaker, Uncertain Ethics Rules in an Uncertain Tax World, University of Virginia, June 3, 2016
- Speaker, It's Not Black & White: Uncertainties in Tax Practitioner Regulation & Ethics, Florida Tax Institute, March 30, 2016
- Panelist, Special Rules for Professionals: Return Preparer Penalties and Ethical Standards, Practicing Law Institute, March 14, 2016
- Panelist, The Administrative Procedure Act and Treasury Regulations, Federal Bar Association, March 4, 2016
- Speaker, Ethical Issues in Setting Engagement Terms, ABA Tax Section, January 29, 2016
- Speaker, Ethics: "Ch-ch-ch-ch-changes, Turn and Face the Strange Times in Regulating Tax Practitioners", The University of Texas School of Law, 13th Biennial Parker C. Fielder Oil and Gas Tax Conference, November 20, 2015
- Speaker, "Traps All Tax Practitioners Should Know and Avoid", William & Mary Law School Tax Conference, November 13, 2015
- Speaker, "Ethical Issues for Tax Practitioners: Good Tax Planning, Aggressive Tax Advice, or Criminal Tax Evasion?", NYU 74th Institute on Federal Taxation, October 29, 2015
- Speaker, "I Can't Believe I Missed That Deadline - Now What?", Southern Federal Tax Institute, October 19, 2015
- Speaker, "Using FOIA in Examinations and Litigation", American Law Institute, October 9, 2015
- Chair, Handling a Tax Controversy: Current Trends in Civil Tax Controversies and Litigation, American Law Institute Continuing Legal Education (ALI CLE), October 8, 2015
- Speaker, Tax Transparency: The Good, The Bad, and The Future, Tax Analysts, September 22, 2015
- Speaker, Oversight Responsibilities in Tax Practice Under Circular 230 §10.36, 2015 Joint Fall CLE Meeting, September 18, 2015
- Christopher Rizek to Serve on Planning Committtee for 7th Annual Tax Controversy Forum, New York University, School of Professional Studies, 7th Annual Tax Controversy Forum, June 5, 2015
- Panelist, Discovery in Tax Court, Duke University School of Law, United States Tax Court 2015 Judicial Conference, May 21, 2015
- Speaker, What's a Young Attorney to Do When...?, American Bar Association, Live CLE Webinar, April 8, 2015
- Panelist, Loving and Circular 230, University of Virginia School of Law, Virginia Tax Study Group, March 27, 2015
- Speaker, Special Rules for the Professionals: Return Preparer Penalties and Ethical Standards, Practising Law Institute (PLI), Nuts and Bolts of Tax Penalties 2015: A Primer on the Standards, Procedures and Defenses Relating to Civil and Criminal Tax Penalties, March 20, 2015
- Panelist, Hot Topics in Refund Litigation, Federal Bar Association, Tax Law Conference 2015, March 6, 2015
- Panelist, What's a Young Tax Attorney to Do When....?, American Bar Association, 2015 Midyear Meeting, January 30, 2015
- Speaker, Top 10 Ethics Issues That Get Tax Professionals in Trouble for Malpractice, 62nd Annual Taxation Conference, University of Texas School of Law, December 4, 2014
- Panelist, How Far Can You Go? Ethical and Penalty Issues in Everyday Tax Practice, New York University School of Professional Studies, 73rd Institute on Federal Taxation, November 20, 2014
- Panelist, Professional Responsibility Developments for Tax Professionals, Federal Bar Association, 37th Annual Insurance Tax Conference, November 13, 2014
- Speaker, Civil Tax Penalties, 60th Annual William & Mary Law School Tax Conference, November 7, 2014
- Panelist, Tax Court Procedures: Trial, Briefing, and Decisions, American Law Institute (ALI) CLE, Handling a Tax Controversy: Audit, Appeals, Litigation, & Collections, October 17, 2014
- Moderator, Luncheon Program: Ethical Issues for Lawyers Wearing Multiple Hats, Washington Metropolitan Area Corporate Counsel Association (WMACCA), Nonprofits and Associations Forum: Wearing Multiple Hats - Common Challenges for GCs Advising Related Organizations, October 1, 2014
- Panelist, The Fallout from Loving: How Broad an Impact on Circular 230?, American Bar Association, Ethics and Professionalism CLE, July 16, 2014
- Panelist, How Many Shades of Grey? Current Ethical Issues for Tax Professionals, 66th Annual Virginia Conference on Federal Taxation, June 11, 2014
- Moderator, Ethical Issues in Tax Practice, Federal Bar Association, 26th Annual Insurance Tax Seminar, May 30, 2014
- Moderator, The Fallout from Loving: How Broad an Impact on Circular 230?", American Bar Association, 2014 May Meeting, May 9, 2014
- Speaker, Taxpayers and the IRS: Is it Time for a Bill of Rights?, Tax Analysts, Public Discussion, March 27, 2014
- Speaker, Ethical Challenges for In-House Tax Professionals, Tax Executives Institute (TEI), Houston Chapter, 26th Annual Tax School, February 3, 2014
- Panelist, Ethical Issues for Tax Practitioners: Good Tax Planning, Aggressive Tax Advice, or Criminal Tax Evasion, New York University, 72nd Institute on Federal Taxation, November 21, 2013
- Christopher S. Rizek to Speak at 37th Annual Insurance Tax Conference, December 6, 2012
- Panelist, Penalties, More and More: How to Assess and Deal with Exposures and Seek Relief, The University of Texas at Austin School of Law, 60th Annual Taxation Conference, December 5, 2012
- Panelist, Crossing the Line: Real Life Ethical Issues in Tax Practice, New York University, 71st Institute on Federal Taxation, November 15, 2012
- Moderator, Litigating Section 7408 Actions, American Bar Association, 2012 Joint Fall CLE Meeting, September 14, 2012
- Panelist, Ethics and the Corporate Tax Professional, Tax Executives Institute (TEI), Region VII Annual Conference, June 27, 2012
- Moderator, Important Developments, American Bar Association, 2012 May Meeting, May 11, 2012
- Scott Michel and Christopher Rizek to Speak at the Federal Bar Association's 36th Annual Tax Law Conference, March 2, 2012
- Christopher Rizek to Speak at Taxpayer Reliance on "Formal" and "Informal" IRS Guidance, January 25, 2012
- Panelist, Ethical and Penalty Issues in Tax Practice, New York University, 70th Institute on Federal Taxation, November 16, 2011
- Moderator, Tax Reliance on "Formal" and "Informal" IRS Guidance, American Bar Association, 2011 Joint Fall CLE Meeting, October 21, 2011
- Moderator, Common Evidentiary Issues in Tax Cases, Part II, American Bar Association, 2011 Joint Fall CLE Meeting, October 21, 2011
- Taxes and the Guidance Problem, July 22, 2011
- Chair, Court Procedure & Practice Committee, American Bar Association, 2011 May Meeting, May 6, 2011
- Chair, Court Procedure & Practice Roundtable, American Bar Association, 2011 May Meeting, May 6, 2011
- Circular 230 Important Revisions, February 23, 2011
- Chair, Court Procedure and Practice Committee, American Bar Association, 2011 Midyear Meeting, January 21, 2011
- Moderator, Regulation Validity/Judicial Deference, American Bar Association, 2011 Midyear Meeting, January 21, 2011
- Chair, Effective Use of Experts in the Courtroom, American Bar Association, 2011 Midyear Meeting, January 21, 2011
- Speaker, The Dirty Dozen: Retrospective of the Last 12 Years at the IRS Since Restructuring, Tax Executives Institute, Inc., Virginia Chapter Meeting, November 18, 2010
- Changing Supervisory and Regulatory Landscape, October 4, 2010
- Chair, Court Procedure & Practice Roundtable, American Bar Association, 2010 Joint Fall CLE Meeting, September 24, 2010
- Chair, Opening Remarks - Court Procedure & Practice, American Bar Association, 2010 Joint Fall CLE Meeting, September 24, 2010
- Straight from the Bench: How to Prepare Your Case for Tax Court, June 18, 2010
- Ethical Issues for Tax Practitioners, June 3, 2010
- Panelist, Section 7216 Regulations Governing Disclosure or Use of Information by Return Preparers, Federal Bar Association, March 5, 2010
- Chair, Stipulations in the Tax Court, American Bar Association, 2010 Midyear Meeting, January 22, 2010
- 68th Institute of Federal Taxation, October 18, 2009
- The Top Ten Things That Get Tax Lawyers into Trouble for Malpractice, April 11, 2007
- Best Practices, February 7, 2007
- Speaker, Ethical Issues That Arise in Tax Transactional Practice, New York University, 65th Institute on Federal Taxation, October 22, 2006
Click here for a full list of speaking engagements.
Recent Publications
- "Taxpayer Defeats IRS Penalty in Tax Court for Conservation Easement Transaction,"
with Charles M. Ruchelman, Scott D. Michel, and Jonathan R. Black, Caplin & Drysdale Client Alert, December 21, 2021
- "IRS Will Continue Captive Insurance and Syndicated Conservation Easement Examinations Despite Covid-19 Pandemic,"
with Charles M. Ruchelman, Caplin & Drysdale Client Alert, April 27, 2020
- "Partnership Filing Relief,"
with Mark D. Allison, Charles M. Ruchelman, James E. Salles, and Jonathan R. Black, Caplin & Drysdale Client Alert, April 13, 2020
- "Captive Soft Letter,"
with Charles M. Ruchelman and Jonathan R. Black, Caplin & Drysdale Client Alert, March 31, 2020
- "IRS to Revoke Passports for Seriously Delinquent Tax Debts Starting February 2018,"
with Mark D. Allison and Victor A. Jaramillo, Caplin & Drysdale Client Alert, February 12, 2018
- "Paradise Papers: U.S. Citizens and Residents Required to Report on Offshore Assets,"
with Mark D. Allison, J. Clark Armitage, Peter A. Barnes, and Kirsten Burmester, Caplin & Drysdale Client Alert, November 6, 2017
- "Captive Insurance: State Reporting Obligations for Transactions of Interest,"
with Charles M. Ruchelman, International Law Office, March 3, 2017
- "Captive Insurance Industry Should Be Aware of State Reporting Obligations for Transactions of Interest,"
with Charles M. Ruchelman, Caplin & Drysdale Client Alert, February 10, 2017
- "Syndicated Conservation Easement Transactions Identified as New 'Listed Transactions',"
with Charles M. Ruchelman, International Law Office, January 27, 2017
- "Syndicated Conservation Easement Transactions Identified as New "Listed Transactions","
with Charles M. Ruchelman, Caplin & Drysdale Client Alert, January 3, 2017
- "Captive Insurance: New IRS Tax Reporting Regime Potential for Penalties and Examinations,"
with Mark D. Allison and Charles M. Ruchelman, International Law Office, November 25, 2016
- "Captive Insurance: New IRS Tax Reporting Regime Potential for Penalties and Examinations,"
with Mark D. Allison and Charles M. Ruchelman, Caplin & Drysdale Client Alert, November 3, 2016
- "Congress Enacts New Tax Examination and Collection Regime for Partnerships,"
with Charles M. Ruchelman and Mark D. Allison, International Law Office, January 22, 2016
- "Congress Enacts Entirely New Tax Examination and Collection Regime for Partnerships,"
with Charles M. Ruchelman and Mark D. Allison, Caplin & Drysdale Client Alert, December 10, 2015
- "The Practical Protection of Taxpayers' Fundamental Rights,"
with Scott D. Michel, International Fiscal Association 2015 Basel Congress, August 1, 2015
- "Abusive Small Captive Insurance Companies on IRS 'Dirty Dozen' List,"
with Mark D. Allison and Charles M. Ruchelman, International Law Office, February 27, 2015
- "Abusive Small Captive Insurance Companies Added to IRS "Dirty Dozen Tax Scams","
with Mark D. Allison and Charles M. Ruchelman, Caplin & Drysdale Client Alert, February 13, 2015
- "IRS Power To Regulate Tax Practitioners Slipping Away,"
Forbes, November 10, 2014
- "Recent Changes in Circular 230: Where Are We Now?,"
Real Estate Journal, September 3, 2014
- "IRS Issues Final Regulations on Material Adviser Penalties,"
with Mark D. Allison, International Law Office, August 29, 2014
- "IRS Issues Final Regulations on Material Advisor Penalties,"
with Mark D. Allison, Caplin & Drysdale Client Alert, August 4, 2014
- "LB&I Commissioner Provides Guidance to Examiners and Managers on the Codified Economic Substance Doctrine and Related Penalties,"
with Charles M. Ruchelman and Mark D. Allison, Caplin & Drysdale Client Alert, July 29, 2011
- "Certainty for Reporting Uncertain Tax Positions (UTP) to IRS,"
with Patricia Gimbel Lewis, Caplin & Drysdale Client Alert, October 13, 2010
- "The Malpractice Environment for Tax Lawyers in the United States,"
Practice Exposures for the International Tax Professional in the 21st Century, 37 Tax Management International Journal 431, August 8, 2008
- "'Prior Work' Can Create Ethical and Malpractice Risk,"
ABA Section of Taxation NewsQuarterly, December 1, 2007
- "IRS Sends Mixed Messages to Nonprofis,"
POLITICO, October 16, 2007
- "New Penalties for Tax-Exempt Entities and Managers,"
Caplin & Drysdale, October 1, 2006
- "Thou Shalt Not Profit, Part I: New Penalties for Tax-Exempt Entities and Managers,"
Health Lawyers Weekly, September 8, 2006
- "IRS Launches Settlement Initiative for Certain "Abusive Transactions","
Caplin & Drysdale, January 15, 2006
- "Tax Shelter Reform,"
Caplin & Drysdale, November 1, 2004
- "Stop the Presses (Book Review),"
Law Practice Magazine, September 1, 2004
- "How Safe is Taxpayer Information in the Hands of Congress,"
Caplin & Drysdale, April 1, 2004
- "Section 6700 - IRS's Newly Found Weapon Against Professionals,"
with Daniel B. Rosenbaum, Caplin & Drysdale, April 1, 2004
- "Recent Developments in the Tax Shelter Area,"
Caplin & Drysdale, November 1, 2003
- "Codification of Economic Substance,"
Caplin & Drysdale Memorandum, May 7, 2003
- "Tax Shelters: Treasury Finalizes Tax Shelter Reporting Regulations,"
with Richard W. Skillman, Caplin & Drysdale, April 1, 2003
- "Taxpayer Privacy and Disclosure Issues Will Continue to Touch Us All,"
The Future of American Taxation (Tax Analysts), December 1, 2002
- "Treasury Department Closing the Door on Tax Shelters,"
Washington Business Journal, August 5, 2002
- "Recent Developments in Treasury's Campaign Against Tax Shelters,"
Caplin & Drysdale, April 12, 2002
- "Evaluating and Managing Tax Shelter Risks,"
with Daniel B. Rosenbaum, Caplin & Drysdale, April 12, 2002
- "The Disclosure Debate Rages On … And On,"
89 Tax Notes 419, October 16, 2000
- "Important Points to Remember: The Disclosure Debate,"
89 Tax Notes 301, October 9, 2000
- "Tax-Exempt Bond Issuers Should Welcome an Excise Tax,"
21-2 Municipal Finance Journal 55, June 1, 2000
- "A New Way to Resolve a Factual Issue with the IRS Before Filing a Return,"
with Patricia Gimbel Lewis, Caplin & Drysdale, February 21, 2000
- "Responses to the 'Lurking Marriage Penalty',"
National Law Journal, October 4, 1999
- "When Is Tax Practice 'Legal'?,"
Legal Times, July 5, 1999
Click here for a full list of publications.