Practice Areas

Taxation

Education

J.D., with highest distinction, University of Arizona College of Law, 1978
• Order of the Coif

Colgate University; University of Arizona, 1974, BA Sociology

Admitted In

Martha Patrick is a peer review rated AV® Preeminent attorney who has been recognized by Best Lawyers in America in the field of Tax Law every year since 2008, Super Lawyers of the Southwest in the field of Tax Law every year since its inception in 2007 and Arizona’s Finest Lawyers since its recent inception.

Martha joined Burch & Cracchiolo in 1987 after nine years as a senior trial attorney in the Office of Chief Counsel of the Phoenix and San Diego Districts of the Internal Revenue Service, handling both criminal and civil tax controversies.  She also worked closely with the Criminal Investigation Division of the IRS, providing advice and legal representation in criminal tax investigations.

Certified as a Tax Specialist by the State Bar of Arizona, Martha is a member of the Tax Sections of the American Bar Association and the State Bar of Arizona.  Her practice deals exclusively with tax controversies, handling both civil and criminal matters.  Drawing on her experience with the IRS and her first-hand knowledge of its practices and procedures, as well as over 20 years of experience serving clients in private practice, Martha represents taxpayers involved in civil and criminal tax controversies before the Internal Revenue Service, the Arizona Department of Revenue and other taxing agencies, from the inception of a tax audit, the administrative appeal and litigation before the United States Tax Court, the United States District Court, the Arizona Tax Court, and the federal and state courts of appeal. She also represents clients in tax collection matters, negotiating installment payment agreements, offers in compromise, voluntary disclosure and amnesty matters, and seizure and forfeiture actions.  Martha has considerable experience handling levy enforcement and lien matters, currency violations and all forms of civil and criminal tax investigations.

Honors & Awards

Selected, Best Lawyers in America
• Tax Law – 2008-2011 editions
Selected, Southwest Super Lawyers
• Tax Law – 2007-2012
Selected, Arizona’s Finest Lawyers 2011
Ranked AV® Preeminent™ 5.0 out of 5* in Martindale Hubbell

*AV® Preeminent ™ and BV® Distinguished™ are certification marks of Reed Elsevier Properties Inc., used in accordance with the Martindale-Hubbell certification procedures, standards and policies.

Representative Engagements

Other Relevant Employment

Prior to joining Burch & Cracchiolo, Martha was a senior trial attorney with the Internal Revenue Service, working for nine years in the San Diego and Phoenix District Counsel offices on both criminal and civil matters.

Professional Leadership

Former member, Executive Committee, Tax Law Advisory Commission, State Bar of Arizona

Professional Affiliations

American Bar Association
• Tax Section
State Bar of Arizona
• Tax Section
Maricopa County Bar Association

Reported Cases

Flack v. United States, 1996 WL 628317, 78 A.F.T.R.2d 96-6386, (D.Ariz., Aug. 14, 1996)

Kenney v. C.I.R., T.C. Memo, 1995-431, (U.S. Tax Ct., Sept. 06, 1995)

Universal Insurance Services, Inc. v. C.I.R., T.C. Memo 1994-192, (U.S. Tax Ct., April 28, 1994)

Heggestad v. C.I.R., 91 T.C.778, (U.S. Tax Ct., Oct. 17, 1988)

G. William Hock and Mildred L. Hock v. C.I.R., T.C. Memo, 1987-444 (U.S. Tax Ct., Sept. 02, 1987)

Driggs v. C.I.R., 87 T.C. No. 46, (U.S. Tax Ct., Sept. 30, 1986)

Shasta Industries, Inc. v. C.I.R., T.C. Memo, 1986-377, (U.S. Tax Ct., Aug. 14, 1986)

Olson v. C.I.R., T.C. Memo, 1984-34, (U.S. Tax Ct., Jan. 18, 1984)

Hoskins v. C.I.R., T.C. Memo, 1983-508, (U.S. Tax Ct., Aug. 22, 1983)

Estate of Dean v. C.I.R., T.C. Memo, 1983-276, (U.S. Tax Ct., May 18, 1983)

Davis v. C.I.R., T.C. Memo, 1983-160, (U.S. Tax Ct., March 23, 1983)

Charles Cadwell III v. C.I.R., T.C. Memo, 1982-231, (U.S. Tax Ct., April 29, 1982)

Ballew v. C.I.R., T.C. Memo, 1981-686, (U.S. Tax Ct., Nov. 30, 1981)

Korth v. C.I.R., T.C. Memo, 1981-462, (U.S. Tax Ct., Aug. 26, 1981)

Evans v. C.I.R., T.C. Memo, 1981-413, (U.S. Tax Ct., Aug. 10, 1981)

Hjalmarson v. C.I.R., T.C. Memo, 1981-342, (U.S. Tax Ct., July 01, 1981)

Stanley I. Blake, M.D. P.C. v. C.I.R., T.C. Memo, 1981-41, (U.S. Tax Ct., Feb. 02, 1981)

Furgatch v. Commissioner of Internal Revenue, 74 T.C. 1205 (U.S. Tax Ct., Sept. 09, 1980)

Presentations and Publications

Martha regularly presents before various professional and industry groups on issues relating to tax controversies and IRS rulings.

Attorney News & Announcements

Eighteen Attorneys at Burch & Cracchiolo Named Among Top in Arizona by Southwest Super Lawyers

Three Burch & Cracchiolo Attorneys Receive 2012 Top Lawyers Ranking