This is my opening posting to ALM’s new site. By way of introduction, I am a tax partner at McElroy, Deutsch, Mulvaney & Carpenter in Morristown, New Jersey and past chairman of the Section of Taxation of the New Jersey State Bar Association. As a past IRS Chief Counsel litigator in New York City with an LL.M. in Taxation from NYU School of Law, I have extensive experience in handling federal and state, civil and criminal, tax controversies, and have represented business clients and individuals in a broad variety of tax matters ranging from civil audits to defending criminal tax investigations at both the federal and state levels. Hopefully, by accessing my upcoming postings that expertise will be useful to you because we live in an enhanced tax enforcement climate which will last for the foreseeable future. I like to illustrate that point by thinking of two trains traveling down the same track … in opposite directions. In one train barreling down the track are very aggressive IRS and State tax agents fueled by a need to raise revenue due to the deficits on the federal and state levels. In the other train are individual and business clients who in a struggling economy have been making judgments and taking tax risks that they may not have made and taken ten years ago. It is inevitable that these trains will collide. There will be more contacts from federal and state tax authorities, more audits, more tax disputes and appeals – both administratively and in the Courts. In addition, there will be more tax investigations and tax prosecutions.  It is a target rich environment.  In upcoming posts I will highlight federal and state tax enforcement areas in which I have seen recent activity.