Angelique M. Neal

With over 20 years of experience, Angelique has a national practice that includes all aspects of federal tax law, federal and state tax controversy, and reporting compliance issues with offshore financial accounts and other assets. From Dickinson Wright’s Lansing and Ann Arbor offices, she represents individuals and business clients, from small businesses to multimillion-dollar corporations, including clients with overseas interests.

For more than ten years, Angelique maintained a successful law office in Brighton, Michigan. Before entering private practice, Angelique served as a senior trial attorney in the Office of Chief Counsel to the IRS. She also served as a Special Assistant United States Attorney for the Department of Justice. Angelique uses that knowledge and experience with the IRS to solve tax problems with creative and foresighted solutions.

Angelique recognizes that dealing with tax problems is confusing and stressful, and she also understands that tax issues require patience, understanding, and discretion. Not only does Angelique provide personal, professional services – she is an experienced tax attorney who is prepared to fight for your interests!

Her experience includes:

• IRS and State tax audits, appeals, and litigation
• IRS and State tax collections, including tax liens, levies, garnishments,
• Offers in compromise, innocent spouse claims, and penalty abatement
• Collection alternatives – payment arrangements, hardship
• Federal payroll and employment tax issues
• State sales, use, and withholding taxes
• Worker classification
• Corporate officer liability and trust fund investigations
• IRS civil and criminal tax litigation

Education & Credentials

Education

Michigan State University College of Law

J.D., Magna Cum Laude , 1999

University of California, Los Angeles

B.A., 1996

Bar Admission

  • California
  • Michigan

Acknowledgements

  • BRAVO Award from the IRS for work on tax shelters 

Prominent Assignments

Successfully negotiated penalty reconsideration and penalty abatement for a parent company and its three subsidiaries resulting in penalty abatements and reductions in excess of $3 million.

Represented small business owner under criminal investigation resulting in no charges being filed.

Successfully argued for penalty reconsideration and penalty abatement of penalties assessed under the Affordable Care Act (ACA) resulting in savings to the client in excess of $1,200,000.

Successfully argued for penalty abatement of penalties assessed under the Affordable Care Act (ACA) resulting in savings to the client in excess of $500,000.

Represented medical professional charged with late filing of reporting returns for an employee benefit plan in excess of $250,000 resulting in abatement of the IRS penalties in full, and avoidance of further penalties by the Department of Labor.

Represented music company in IRS civil examination and concluded the examination without any additional tax due.

Negotiated an offer in compromise for client, fully resolving all outstanding tax liabilities for less than 5 percent of the liabilities saving the client in excess of $1.3 million.

Negotiated an Offer in Compromise for the client, fully resolving outstanding individual and trust fund liabilities for less than 5 percent saving the client over $175,000.

Represented multi-million dollar manufacturing company with multi-tiered structure in IRS civil examination and litigation with over $1 million in proposed partnership adjustments, resulting in partnership adjustments of $10,000.

Represented individual before the Michigan Tax Tribunal regarding corporate officer liability for sales, use, and withholding taxes, resulting in the court canceling the final assessments against the individual in full.

Successfully argued for the withdrawal of federal tax liens filed against professionals in the financial services industry, resulting in the liens being removed from public record.

Represented tax return preparer in investigation by the IRS for preparer penalties and injunction resulting in no injunction referral to the Department of Justice and minimal penalties.

Represented small business owners in IRS examination and litigation resulting in a full concession by the government of the additional tax and penalties being asserted by the IRS.

Successfully argued for reconsideration and abatement of Employers Shared Responsibility Payment (ESRP) assessment resulting in substantial savings to the client.

Professional Involvement

  • American Bar Association, Taxation Section
  • Michigan Women’s Tax Association
  • National Association of Tax Professionals
  • State Bar of Michigan, Taxation Section
  • Women Lawyers Association of Michigan

Community Involvement

  • Greater Brighton Area Chamber of Commerce

Court Admissions

  • United States Tax Court
  • United States District Court, Eastern District of Michigan

Publications/Presentations

• The Biden Administration’s First 50 Days Webinar Series, Presenter
• Legal Talk Today, President Trump’s Deferral of Payroll Taxes, Presenter
• Stafford Publications: Delinquent Taxpayers – Avoiding Passport Revocations,
Statutes of Limitations, OICs and Penalties (7/24/2019), Presenter
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