Jenny Louise Johnson

Jenny Louise Johnson is co-chair of the Tax Controversy Practice. Ms. Johnson has substantial experience handling criminal and civil tax disputes. She represents clients through all stages of criminal and civil tax investigations and litigation, including sensitive audits and examinations, search warrants, grand jury subpoenas, negotiated resolutions with the IRS and the Department of Justice, trials in federal district court and Tax Court, sentencings, and appeals. Working closely with other attorneys in the firm, Ms. Johnson handles disputes involving income taxes, estate and gift taxes, excise taxes, employee plan matters, and tax exempt bonds. Ms. Johnson's recent criminal defense experience involves a lengthy jury trial, two successful appeals to the Court of Appeals for the Seventh Circuit, frequent representation of targets, subjects and witnesses in grand jury investigations, negotiation of numerous plea agreements, and sentencings in which her clients received punishments well below the guideline range. On the civil side, Ms. Johnson recently tried two cases on the same Tax Court docket, one of which was the first case involving a “Midco” listed transaction to be tried in the Tax Court. Ms. Johnson has also attained favorable settlements of many disputes with the IRS, before or during litigation, and routinely provides behind-the-scenes strategic counseling to clients and their other advisors on potential or existing tax-related disputes.

In addition to handling employee plan qualification disputes with the IRS, Ms. Johnson is a key member of the firm’s ERISA Litigation Practice, representing plans, plan sponsors, and fiduciaries in both investigations and litigation. Drawing on the depth of expertise in ERISA and ESOPs in the firm's Employee Benefits Practice, Ms. Johnson has recently represented an independent trustee of an ESOP in an investigation by the Department of Labor, and litigated on behalf of trustees alleging that other fiduciaries violated ERISA by breaching their fiduciary duties and engaging in prohibited transactions. Ms. Johnson also recently played a significant role representing a plan sponsor who faced an IRS threat of disqualification of its qualified plans, culminating in a favorable closing agreement after protracted negotiations that involved the highest-ranking Employee Plans officials in the IRS. 

Ms. Johnson also continues to represent clients in other types of complex litigation, including cases involving intellectual property, health care fraud, financial crimes, RICO, Foreign Corrupt Practices Act, and commercial disputes. Ms. Johnson is particularly interested in the criminal enforcement of intellectual property rights, which combines her knowledge of trademark and copyright law with her experience conducting investigations and handling criminal cases. Ms. Johnson is dedicated to the provision of pro bono services, and received the firm's Pro Bono Award in 2005 in recognition of her commitment to representing children who are charged with crimes. She continues to represent children in juvenile delinquency proceedings, immigrants seeking asylum, and those who have been wrongly convicted.