Randall P. Andreozzi

Mr. Andreozzi’s legal career has focused on resolution of complex tax controversy matters, large case (corporate) tax matters, tax shelter litigation, employee welfare benefit litigation, and international/territorial tax issues.

For 16 years, Mr. Andreozzi worked for the IRS Office of Chief Counsel, where he served as Industry Counsel for the Commissioner's Industry Specialization Program (ISP). He evaluated and litigated tax cases presenting Welfare Benefit Plan issues. Mr. Andreozzi litigated many seminal cases in this area, including General Signal Corp. v. Commissioner, Booth v. Commissioner, Parker Hannifin Corporation v. Commissioner, Square D Co. v. Commissioner and Neonatology Associates v. Commissioner. He also assisted and counseled other IRS attorneys and revenue agents in their development of cases under the ISP program, offering valuable expertise in areas involving tax shelters and the corporate income tax consequences of VEBAs and Welfare Benefit Plans.

During his years with the IRS Chief Counsel's office, Mr. Andreozzi cultivated a strong reputation with attorneys and agents throughout IRS, as well as with outside tax practitioners nationwide. His extensive trial experience extends to other complex tax areas as well. Mr. Andreozzi tried a variety of complex precedential cases that have established important precedent in the areas of abusive tax shelters, corporate acquisitions (INDOPCO v. Commissioner), international taxation, United States Virgin Islands territorial taxation, and TEFRA partnerships. 

Mr. Andreozzi is an Adjunct Professor at the State University of New York (SUNY) at Buffalo School of Management, where he teaches Business Law at both the graduate and undergraduate levels. While he was with the IRS Chief Counsel's office, he also trained Chief Counsel attorneys at national litigation schools. He has also served as an adjunct instructor at Bryant & Stratton Business Institute, where he taught Business Law, English, and Management in the Undergraduate Program.

AWARDS AND HONORS

• Office of Chief Counsel National Litigation Award (1997 and 2000)
• Western Region Chief Counsel Litigation Trophy (1997)
• Assistant Commissioner (Examination) Award (1995)

    ACADEMIC DEGREES

• JD State University of New York at Buffalo
• BA Canisius College English (Honors)
• BA Canisius College Political Science

    LICENSES / CERTIFICATION

• New York State
• United States Tax Court
• United States Federal District Court,
• Western District of New York

Randall Andreozzi can be reached via our contact form or telephone (716) 565-1100 ext. 302.