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Courtney A. Hopley represents clients in federal and state tax controversies before the IRS and the California Franchise Tax Board at the audit, collection, appeals and litigation stages. She works on tax controversy matters involving partnerships, corporations, individuals, real estate and penalty disputes. Courtney also has experience in tax planning involving entity formation, mergers and acquisitions, and reorganization transactions.


  • Civil tax controversies
  • Tax compliance advice
  • Tax shelter investigations, audit and litigation
  • Tax penalties



  • Represented group of related taxpayers in case involving complex partnership transaction.
  • Successfully defended multiple taxpayers in residency matters involving the California Franchise Tax Board.
  • Defended taxpayer in civil forfeiture action involving inadvertent violation of the structuring rules.
  • Drafted Private Letter Ruling Request involving late I.R.C. Section 663(b) election.
  • Assist taxpayers in residency planning.
  • Advised financial institution regarding penalty exposure for in-house tax return preparation activities.
  • Advised family office regarding procedures for protecting attorney-client privilege.
  • Drafted tax opinions regarding various tax issues.
  • Represented taxpayers in tax audits involving FBAR and other international tax penalties.
  • Obtained penalty abatements involving accuracy, delinquency, trust fund recovery, employment tax penalties.

Recognition & Leadership

  • Listed, The Legal 500 United States, US Taxes: Contentious, 2021 
  • Listed, Super Lawyers magazine, Northern California Super Lawyers, "Rising Stars," 2013-2020
  • Member, American Bar Association, Taxation Section
  • Member, California State Bar, Taxation Section
    • Member, Executive Committee, 2016-Present
    • Chair, Tax Procedure & Litigation Subcommittee, 2015-2016
  • Member, San Francisco Tax Club


  • LL.M., Taxation, New York University School of Law, 2007
  • J.D., University of Colorado Law School, 2006
  • B.A., Colorado College, 2003
    • Member, Phi Beta Kappa
  • California
  • Colorado
  • U.S. Tax Court