Patrick represents clients in civil tax collection and examination matters, both in administrative proceedings and in litigation before the United States Tax Court, as well as other federal and state courts. He also advises clients on federal, state, and local tax matters, such that his clients might mitigate and avoid costly downstream civil tax disputes.
Prior to coming to Frost Brown Todd, Patrick was the founding director of Notre Dame Law School’s Tax Clinic, in which he trained and supervised upper-level law students representing low-income clients in disputes with the Internal Revenue Service. He also designed and taught the Tax Clinic’s seminar course each semester, which focused on core lawyering skills, federal tax procedure, and substantive federal and state tax law. In 2016, he received an American Bar Association Section of Taxation Public Service Fellowship, through which he worked as a staff attorney for the Low Income Taxpayer Clinic at the Neighborhood Christian Legal Clinic in Indianapolis.
Patrick is active in leadership and publication roles with the American Bar Association’s Section of Taxation. In addition to speaking on and planning numerous CLE panels, Patrick is the current co-editor in chief of the ABA Section of Taxation’s two-volume treatise, Effectively Representing Your Client Before the IRS. Patrick has also volunteered his time to the Tax Section in drafting various responses to government commentary requests, such as on the draft Form 1040 for 2018 and proposed regulations defining the definition of a tax dependent. He is also a contributor to Procedurally Taxing, a blog that considers developments in federal tax procedure and tax administration.
Patrick earned his J.D. from the Indiana University Maurer School of Law, cum laude and his B.A. from Indiana University, summa cum laude. While in law school, he directed Indiana University’s Volunteer Income Tax Assistance program and founded the law school’s Pro Bono Immigration Project.
Negotiate settlements with the U.S. Department of Justice in tax collection and refund suits.
Represent taxpayers in civil tax controversies—including tax assessment, collection, and refund disputes—in both litigation as well as administratively before the IRS and Indiana Department of Revenue.
Negotiate offers in compromise and other alternatives to levies and enforced tax collection.
Negotiated a $25 million reduction in proposed federal income tax liabilities, along with an attorney’s fees award, in an innocent spouse matter in the United States Tax Court.
Filed federal lawsuit seeking class action status on behalf of taxpayers from whom the IRS unlawfully withheld economic stimulus payments.
Negotiated favorable settlement in a Foreign Bank Account Report penalty suit
Indiana University Maurer School of Law, J.D., 2013
Indiana University, B.A., International Studies; German; Arabic, 2009
summa cum laude
United States Tax Court
U.S. District Court for the Northern District of Indiana
Indiana State Bar Association, Leadership Development Academy (2019)
Indiana Department of Revenue, Commissioner’s Tax Advisory Council (2017-2021)
American Bar Association, Section of Taxation, Christine A. Brunswick Public Service Fellow (2014 – 2016)
American Bar Association,
Section of Taxation, Vice-Chair, Individual and Family Taxation Committee (2019 – Present)
Indiana State Bar Association, Tax Section
Neighborhood Christian Legal Clinic, Young Professional Advisory Board, Chair (2021 – Present)
Neighborhood Christian Legal Clinic, Board of Directors, Member (2021 – Present)
University of Notre Dame, Community Engagement Coordinating Council (2018 – 2021)
Notre Dame Law School, Loan Repayment Assistant Program Committee (2016 – 2021)
Protecting Vulnerable Taxpayers Against Tax Preparer Fraud, ABA Section of Taxation Fall Meeting 2021
Working with Taxpayers with Disabilities, ABA Section of Taxation May Meeting 2020
Designated Orders in the U.S. Tax Court, ABA Section of Taxation Midyear Meeting 2020
Roundtable Discussion for Academic Tax Clinics, 2020 Low Income Taxpayer Clinic Grantee Conference (Dec. 2019)
The IRS Violated My Client’s Religious Liberties: When is This Unlawful and What Can We Do About It?, ABA Section of Taxation Fall Meeting 2019 (moderator)
Advocating Before State Taxing Agencies, 2019 Low Income Taxpayer Clinic Grantee Conference (Dec. 2018)
Recent U.S. Tax Court Designated Orders, 2019 Low Income Taxpayer Clinic Grantee Conference (Dec. 2018)
Crafting Tax-Compliant Divorce & Custody Agreements After Tax Reform, St. Joseph County Bar Association, Mar. 2018
Section 104(a)(2) and the Taxation of Damages Received Pursuant to a Settlement Agreement, ABA Section of Taxation Midyear Meeting 2018 (moderator)
Tax Effects of the DACA Repeal on Immigrant Families, ABA Section of Taxation Midyear Meeting 2018 (moderator)
Civil Rights Responsibilities and Serving People with Mental Illness, 2018 Annual LITC Grantee Conference (Dec. 2017)
Crafting Tax-Compliant Divorce & Custody Agreements, St. Joseph County Bar Association, Oct. 2017
Operation of a Small Business, Low Income Taxpayer Representation Workshop May 2017 (moderator)
Section 152 Proposed Regulations, ABA Section of Taxation May Meeting 2017 (panelist)
IRS Notice 2017-15: Same-Sex Marriage and Retroactivity, ABA Section of Taxation May Meeting 2017 (moderator)
Deductible Medical Expenses under Section 213, ABA Section of Taxation Midyear Meeting 2017 (moderator)
EITC Bans under IRC Section 32(k), 2017 Low Income Taxpayer Clinic Grantee Conference (panelist)
Jurisdictional Issues: The EITC Ban, ABA Section of Taxation May Meeting 2016 (panelist)
The PATH Act: Changes Affecting Immigrant Families and the Challenges Ahead, ABA Section of Taxation May Meeting 2016 (panelist)
Ethical Issues for Newer Attorneys, ABA Section of Taxation Fall Meeting 2015 (panelist)
Handling Cases with Potential Criminal Issues, ABA Section of Taxation May Meeting 2015 (moderator)
Effectively Representing Your Client Before the IRS (with C. Speidel, eds., 8th ed. 2021).
ABA Section of Taxation, Comments on Guidance Regarding Draft 2018 Form 1040 and Related Schedules (principal author of public commentary on proposed Form 1040)
Assisting Taxpayers with Disabilities (with C. Thompson), in Effectively Representing Your Client Before the IRS (T. Keith Fogg, ed., 7th ed. 2018).
ABA Section of Taxation, Comments on the Definition of Dependents [Reg-137604-07] (contributor to public commentary on proposed IRS regulations)
Being Your Own Boss: The Career Trajectories and Motivations of India’s Newest Corporate Lawyers (with J.K. Krishnan), in The Indian Legal Profession in the Age of Globalization (eds., David B. Wilkins, Vikramaditya Khanna, & David Trubek, Cambridge University Press, 2017).
Surveying Key Aspects of Sociolegal Scholarship on India: An Overview, 11 Ann. Rev. L. Soc. Science 337 (2015) (with J.K. Krishnan)
Note, The Recurring Native Response to Global Labor Migration, 20 Ind. J. Global Legal Stud. 1393 (2013)