Randall P. Andreozzi
PARTNER
Randall P. Andreozzi
PARTNER

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.
Now in private practice with the firm of Andreozzi Bluestein LLP, Mr. Andreozzi continues to focus his practice on complex tax litigation and tax controversy resolution. His practice areas include international taxation and foreign bank account reporting, criminal tax and financial crime defense, employee benefit taxation, tax shelter litigation, and a variety emerging areas of federal and state tax law.
Mr. Andreozzi has published numerous articles on taxation, and frequently lectures on a variety of current and developing tax issues. He 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 Office of Chief Counsel, he trained Chief Counsel trial attorneys at national litigation schools.
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
- United States Court of Appeals for the Second Circuit
- United States Court of Appeals for the Third Circuit
More Articles from Randall P. Andreozzi
Finally Some Good News! — Congress Locks In Full PPP Deductibility
By: Randall P. Andreozzi Congress last night passed COVID-relief legislation that included a much-anticipated provision that allows businesses to deduct qualifying expenses paid with forgiven ...
Read moreIRS Captive Insurance Global Settlement Offer- Know your options.
By: Randall P. Andreozzi, Esq. In 2016 the IRS issued Notice 2016-66, which identifies certain micro captive insurance transactions as potentially abusive. The Notice generally describes the ...
Read moreOur View on Cryptocurrency Taxes & the IRS
By: Randall P. Andreozzi, Esq. Cryptocurrency investors be warned. The IRS is coming for you. Over the course of several years, the IRS has methodically ramped up its efforts to tackle the ...
Read moreThink the IRS is quiet during the Shutdown? Think Again! Another Form 3520 Trap for the Unwary
By: Randall P. Andreozzi Things are emerging from the abyss that is the longest government shutdown in United States history. Yes, there exist some things so resilient, so pervasive, so constant ...
Read moreIRS Offshore Voluntary Disclosure Program Will End on September 28, 2018
By: Randall P. Andreozzi, Esq. The IRS announced on Wednesday that it will officially end the 2014 Offshore Voluntary Disclosure Program (affectionately known to practitioners as the “OVDP”) on ...
Read moreAndreozzi Bluestein Litigators Achieve Precedential Tax Court Victory for United States Virgin Islands Taxpayers
In a court-reviewed opinion published on January 29, 2018, the U.S. Tax Court in Coffey, et. al. v. Commissioner, 150 T.C. No. 4, found in favor of the taxpayers and dismissed the Internal Revenue ...
Read moreThe Threat of Parallel Investigations: When Civil Isn’t Civil
By: Justin J. Andreozzi, J.D.; Randall P. Andreozzi, J.D.; and Arlene Hibschweiler, MBA, J.D. While at one time, the IRS would discontinue a civil examination when it began a criminal investigation ...
Read moreRecent Revisions to the IRS Offshore Voluntary Disclosure Programs
By: Randall P. Andreozzi Recent revisions to the IRS Offshore Voluntary Disclosure Programs illustrate that the Service is becoming more aggressive and less tolerant with those taxpayers who have not ...
Read moreWe are a law firm built on Experience, Vision & Trust
Whether you need tax counsel for litigation, representation before the IRS, an advocate in tax controversies, or thorough tax analysis and objective consulting, our attorneys have the experience and obtain lasting solutions.