Paula M. Junghans_bio
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Paula M. Junghans

Partner

Office
Washington, DC
Baltimore
Tel.
+1 202.778.1850
Fax.
202.822.8106
Others
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Described by a client as “the most complete lawyer I have ever known” in Chambers USA, Paula M. Junghans is a seasoned trial lawyer who has tried complex cases in courts throughout the United States. 

Paula has more than 40 years of experience in federal tax litigation and white collar criminal matters and has the valuable perspective of having served both as a defense lawyer and a supervising prosecutor.

As a prosecutor and Acting Assistant Attorney General of the Tax Division of the U.S. Department of Justice, she supervised the litigation of tax cases throughout the United States. In her current practice, she draws on her experience in tax procedure, as well as in the interrelationship between criminal and civil tax issues, to counsel individuals and businesses on complex investigations and prosecutions.

In addition to tax controversies, she has represented individuals involved in a wide array of federal criminal investigations and prosecutions involving conspiracy, mail and wire fraud, bank fraud, health care fraud, currency transactions offenses, environmental crime, and money laundering.

Paula co-authored a treatise on federal tax litigation, and she is a frequent speaker and writer on matters involving tax procedure and white collar crime. She is a fellow of the American College of Trial Lawyers and the American College of Tax Counsel.

Education
  • University of Maryland School of Law, J.D., 1976
     
  • College of Notre Dame of Maryland, B.A., cum laude, 1971
Bar admissions
  • District of Columbia
  • Maryland
Court admissions
  • U.S. Supreme Court
  • U.S. Tax Court
  • U.S. Court of Federal Claims
  • U.S. Court of Appeals, Federal Circuit
  • U.S. Court of Appeals, Fourth Circuit
  • U.S. Court of Appeals, Fifth Circuit
  • U.S. Court of Appeals, Sixth Circuit
  • U.S. Court of Appeals, Ninth Circuit
  • U.S. Court of Appeals, Tenth Circuit
  • U.S. District Court, District of Maryland
Government service
  • Acting Assistant Attorney General
    • Tax Division
    • U.S. Department of Justice
Professional leadership
  • American College of Tax Counsel, 1994–present
  • Fellow, American College of Trial Lawyers
Representative matters
  • Represented former head of US private banking at large Swiss bank; negotiated plea agreement and successfully argued for probationary sentence.
  • Representing attorneys in promoter penalty investigation. 
  • Representing foreign trusts in examinations involving income tax issues, foreign withholding, and information return penalties arising out of substantial investments in US businesses.
  • Litigating a case in the Court of Federal Claims related to alleged cancellation of indebtedness income.
  • Resolved examination of large sub-S corporation and sole shareholder related to use of corporate aircraft.
  • Challenged prohibited transaction penalties asserted against former executive of non-profit entity; all penalties abated. 
  • Represented an entity and two related individuals in promoter examination; resolved without assertion of any penalties.
  • Resolved a promoter penalty examination of accounting firm related to conservation easements.  
  • Resolved a high-net worth examination of major international businessman.
  • Defended the former CEO of Westar, an electrical utility, in a criminal prosecution in the U.S. District Court for the District of Kansas for wire fraud, conspiracy, money laundering, and circumventing internal company controls. This case, which the press dubbed the “Enron of Kansas,” involved two trials—the first ended in a hung jury; the second ended in convictions that the U.S. Court of Appeals, 10th Circuit overturned. All charges against the client were dismissed prior to a scheduled third trial.
  • Represented a commercial aviation leasing company and its president and CEO in a seven-week jury trial in the U.S. District Court for the Northern District of Illinois. The U.S. Securities and Exchange Commission sued the company and its president in 2007, alleging that the company was insolvent and was misusing investors’ funds, but we defeated the SEC’s effort to appoint a receiver and freeze the company’s assets. In 2010, a criminal indictment alleging various wire fraud, bank fraud, tax, and obstruction of justice offenses was returned. 
  • Represented the lead defendant in one of the largest tax shelter cases ever brought in a two-month criminal fraud trial. The client, who had been a partner at the accounting firm of Ernst & Young (E&Y), was indicted with three other E&Y partners on multiple counts, including tax evasion and obstruction of justice. The case centered on the legality of certain tax shelters that were marketed to high-net-worth individuals and designed to reduce, or eliminate, income taxes. It also involved complex tax transactions and novel issues of criminal liability arising from the conduct of professionals engaged in tax planning. 
  • Defended an accountant who was accused of providing fraudulent tax planning advice by counseling customers on how to reduce their federal tax liabilities. The government filed an injunction proceeding against the client to forbid him, his son, and his companies from preparing tax returns—a move that would effectively destroy his business and livelihood. After an evidentiary hearing, the court denied the motion for preliminary injunction. Of the more than 400 similar injunction actions brought by the Tax Division of the U.S. Department of Justice in the last several years, this is one of a very few in which the return preparer prevailed. 
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Paula M. Junghans_bio

Paula M. Junghans

Partner

Office
Washington, DC
Baltimore
Tel.
+1 202.778.1850
Fax.
202.822.8106
Others
Send an Email
vCard
LinkedIn