Anton L. Janik, Jr.

Member

Bar Admissions: Arkansas, Colorado
Language(s): Russian

Education

B.A. Middlebury College, 1995
J.D. University of Denver, 2003, Order of St. Ives
LL.M. in Taxation, Georgetown University Law Center, 2007
Admitted to practice in Arkansas
Admitted to practice in Colorado
United States District Court, Eastern and Western  Districts of Arkansas
United States Tax Court
United States Supreme Court

Professional Experience

Mr. Janik leads the Tax Controversy and Litigation practice on behalf of Mitchell Williams and serves as a member of the Government Investigations, Enforcement & White Collar Crime and the Information Management & Security teams.

In his tax practice, Mr. Janik represents corporations, partnerships, and high net worth individuals in both domestic and international tax matters before county, state and federal taxing authorities, and at whatever procedural step matters arise—including the planning and developmental stage, during the administrative process at federal, state and local examination and appeals, through the various alternative dispute resolution programs, and through litigation in state courts, as well as the Tax Court, Federal District Courts, Court of Federal Claims, United States Courts of Appeal and the United States Supreme Court.

Mr. Janik’s Governmental Investigations practice includes defending corporations and persons during state and federal governmental investigations and litigation. His eDiscovery practice includes extensive experience with managing large scale eDiscovery projects utilizing the latest technology to maximize throughput and minimize cost.

Prior to joining the firm, Mr. Janik was a Trial Attorney with the U.S. Department of Justice in Washington, D.C. Mr. Janik joined the Department of Justice through the Tax Division’s Honors Program. While at the Department of Justice, Mr. Janik represented the Internal Revenue Service and practiced in the federal district and bankruptcy courts throughout the Ninth and Tenth Circuits.

Mr. Janik was awarded the U.S. Attorney General’s Outstanding Attorney Award in both 2005 and 2006.

Reported Cases

Tax Shelter Investigations:

Central Valley Ag Enterprises v. United States, 326 B.R. 807 (E.D.Cal. 2005) (IRS Notice 2003-55/Offshore Lease Strip Transactions)

In the Matter of Tax Liabilities of John Does (In re Paypal, Inc.), 05-cv-4167 JW (N.D.Cal. 2005) (IRS Rev. Proc. 2003-11/Offshore Voluntary Compliance Initiative)

Sala v. United States, 99 A.F.T.R.2d 2007-1709 (D.Colo. 2007) (IRS Notice 2000-44/Son of B.O.S.S.)

Corporate Investigations:

Colorado Gas Compression, Inc. v. United States, 98 A.F.T.R.2d 2006-7501 (D.Colo. 2006) (IRS Investigative Summons)

United States v. Little John Trucks, Inc., Case No. 11-cv-492 (E.D.Ar. 2011) (Reduce Assessments to Judgment)

United States v. Montgomery Global Advisors V LLC, Case No. 03-cv-733 (2006) (IRS Investigative Summonses and Criminal Contempt)

Vision Service Plan v. United States, 96 A.F.T.R.2d 2005-7440 (E.D.Cal. 2005) (Revocation of Tax Exempt Status)

Other Tax Matters:

Abell v. Sothen, 97 A.F.T.R.2d 2006-1804 and 1815 (D.Colo. 2006) (IRS Collections Summons)

ARM Financial Corp. v. Daniel Ahlstrom, Case No. 03-cv-1264 (D.Nev. 2005) (Interpleader)

Austin v. Archoice, LLC, Case No. CV 2006-3868 (Pulaski County 2010) (Quiet Title/Tax Seizure)

Cal-Western Reconveyance Corp. v. Residential Property, Case No. 04-cv-564 (S.D.Cal. 2004) (Interpleader)
 
United States v. Community First National Bank – East, Case No. 03-cv-155 (D.Wyo 2003) (Reduce Assessment to Judgment and Foreclosure)

Devin v. United States, 423 F.Supp.2d 1232 (D.Wyo. 2006) (Enforceability of Tax Compromise Agreement)

Frymark v. United States, Case No. 02-cv-845 (D.Md. 2004) (Responsible Officer/Trust Fund Recovery Penalty)

Green v. United States, 434 F.Supp.2d 1116 (D.Utah 2006) (Foreclosure Redemption)

Hernandez v. State of Wyoming, Case No. 04-cv-134 (D.Wyo. 2004) (Separation of Powers Between State and Federal Governments in Tax Collection)

Holman v. United States, 95 A.F.T.R.2d 2005-1165 (D.Utah 2005) (Nominee Asset Transfer)

In re Pugh, 315 B.R. 889 (B.Nev. 2004) (Responsible Officer/Trust Fund Recovery Penalty)

Jones v. United States, Case No. 03-cv-762 (D.Colo. 2003) (IRS Collections Summons)

Leach v. United States, 98 A.F.T.R.2d 2006-6199 (D.Mont. 2006) (Tax Exempt Securities)

Lee v. Bass, 345 F.Supp.2d 947 (D.Mont. 2004) (Anti-Injunction Act)

Liniger v. United States, Case No. 05-cv-381 (D.Colo. 2005) (Hobby Losses)

Lister v. United States, Case No. 03-cv-662 (D.Utah 2004) (Collections Due Process)

Murphy v. Marker, et al., 97 A.F.T.R.2d 2006-2209 (D.Utah 2006) (IRS Collections Summons)

Renn v. Wilfley (In re Wilfley), Case No. 06-3231 (B.Or. 2006) (Alleged Tax Fraud)

Rosson v. United States, 127 Fed.Appx. 398 (10th Cir. 2005) (Anti-Injunction Act)

Smith v. United States, 98 A.F.T.R.2d 2006-8093 (D.Utah 2006) (Responsible Officer/Trust Fund Recovery Penalty)

Stanojevich v. United States, Case No. 05-mc-9141 and 05-mc-1299 (D.Or. 2005) (9th Cir. 2006) (IRS Collections Summons)

United States v. Travers, Case No. 03-cv-2112 (E.D.Cal. 2004) (Priority of Tax Liens)

Other Activities

Adjunct Professor, UALR College of Business
Board Member, Arkansas Zoological Foundation
Board Member, Downtown Little Rock Partnership (Chairman, Safety Subcommittee)
Board Member, Arkansas Foodbank Network
President, Arkansas Foodbank Network Harvesters
Committee Member, Judicial Nominations Committee, Arkansas Bar Association
Member, UAMS Consortium
Member, Arkansas Children’s Hospital Foundation Professional Advisory Council
Senior Tax Controversy Advisor, THE TAX LAWYER (2006-2007)
Staff Editor, Denver University Law Review
Managing Editor, Denver Journal of International Law and Policy

Publications

Prosecuting al Qaeda: America’s Human Rights Policy Interests Are Best Served By Trying Terrorists Under International Tribunals, 30 Denv. J. Int’l. L. & Pol’y 498 (2002)

Combating the Illicit Internet: Decisions by the Tenth Circuit to Apply Harsher Sentences and Lessened Search Requirements to Child Pornographers Using Computers, 79 Denv. U. L. Rev. 379 (2002).