Christopher Gurley
Overview
Chris advises clients in preparing for, defending, and resolving tax disputes. Chris is located in Crowell & Moring’s Los Angeles offices, where he practices in the Tax Group. Chris’ practice focuses on both federal and state tax controversy and litigation. Chris guides clients through all stages of tax controversies, including IRS audits to administrative appeals, alternative dispute resolution proceedings, and litigation. Chris also has extensive experience representing taxpayers before the California Franchise Tax Board. Additionally, Chris has practiced in the Antitrust and Competition Group, pursuing and maximizing claims in complex antitrust settlements on behalf of a broad range of national and international clients.
Career & Education
- United States Tax Court
Attorney–Advisor and Law Clerk to the Honorable Joseph Robert Goeke, 2014–2015
- United States Tax Court
- Georgetown University Law Center, LL.M., Taxation
- Howard University School of Law, J.D.
- Morehouse College, B.A., cum Laude, Business Administration–Finance
- California
- Illinois
- District of Columbia (Inactive)
- U.S. Tax Court
- U.S. Court of Federal Claims
Professional Activities and Memberships
- American Bar Association, Section of Taxation, Diversity Committee, Vice-Chair, 2024–Present
- HealthRight 360, Board Member, 2020–2024
Christopher's Insights
Client Alert | 3 min read | 08.13.25
Faster Audits, More ADR: IRS Rolls Out Significant LB&I Changes
On July 23, 2025, the Internal Revenue Service (“IRS”) issued interim guidance for Large Business & International Division (“LB&I”) audit procedure. The IRS announced three major changes: (1) the Acknowledgement of Facts Information Document Request (“AOF IDR”) will be eliminated; (2) Accelerated Issue Resolution (“AIR”) applies to Large Corporate Compliance (“LCC”) cases; and (3) the IRS must conduct additional review before denying a taxpayer’s request to participate in the Fast Track Settlement (“FTS”). These changes reflect the IRS’s continued push to make its examinations “more efficient and current.”
Client Alert | 4 min read | 07.24.25
Client Alert | 2 min read | 05.22.25
What Trump’s Nominee for IRS Commissioner Could Mean for Employee Retention Tax Credit Enforcement
Client Alert | 2 min read | 05.16.25
Insights
TEI Seattle
|12.10.24
“Critical Developments in Information Reporting and Electronic Filing: Broader Reach, New Requirements, and Increased Audits,” TEI's 2024 Midyear Conference, Washington, D.C.
|03.18.24
Christopher's Insights
Client Alert | 3 min read | 08.13.25
Faster Audits, More ADR: IRS Rolls Out Significant LB&I Changes
On July 23, 2025, the Internal Revenue Service (“IRS”) issued interim guidance for Large Business & International Division (“LB&I”) audit procedure. The IRS announced three major changes: (1) the Acknowledgement of Facts Information Document Request (“AOF IDR”) will be eliminated; (2) Accelerated Issue Resolution (“AIR”) applies to Large Corporate Compliance (“LCC”) cases; and (3) the IRS must conduct additional review before denying a taxpayer’s request to participate in the Fast Track Settlement (“FTS”). These changes reflect the IRS’s continued push to make its examinations “more efficient and current.”
Client Alert | 4 min read | 07.24.25
Client Alert | 2 min read | 05.22.25
What Trump’s Nominee for IRS Commissioner Could Mean for Employee Retention Tax Credit Enforcement
Client Alert | 2 min read | 05.16.25
