Attorneys

Guy C. Crowgey was born in Charlottesville, Virginia and raised in Roanoke, Virginia. He received his Bachelor’s degree in 1983, law degree in 1986 from the T.C. Williams School of Law at the University of Richmond, and Masters of Laws in Taxation in 1987 from the Marshall-Wythe School of Law at the College of William and Mary.

He has worked in various small and medium sized law firms in downtown Richmond, Virginia for over three decades, including serving as Special Counsel to the Division of Legislative Service for the Senate Finance Committee of the Virginia General Assembly in 1994. He was a principle in the law firm of Eck, Collins & Marstiller before forming the predecessor law firm of Crowgey & Associates in 2003.

Mr. Crowgey has extensive experience in both Federal and State tax controversy issues and has an excellent working relationship with officials within both the Small Business – Self Employed Division

of the Internal Revenue Service and the Virginia Department of Taxation in dealing with tax controversy issues including collection, audits and appeals. Mr. Crowgey has successfully litigated cases in United States District Court and Virginia Circuit Courts in favor of his clients against various federal, state and local taxing authorities including, in particular prevailing in a case in the U.S. District Court in South Carolina and successfully obtaining legal fees from the Internal Revenue Service for improper filling of federal tax liens against his client. Mr. Crowgey also has extensive involvement with the Appeals Division of the IRS and Area Counsel for the IRS and has resolved numerous Federal and State criminal tax cases with special agents from the Criminal Investigation Division of the Internal Revenue Service and local Commonwealth’s Attorney’s offices.

Mr. Crowgey also has considerable experience in complicated and difficult litigation cases. He is an active member of the Virginia State Bar, and over the years has acted in numerous roles, including serving six years on the Virginia State Bar Council for the 13th Judicial District and six years on the Board of Governors of the Virginia State Bar Tax Committee. Mr. Crowgey also served previously as Vice-Chair of the Virginia State Bar Standing Committee of Unauthorized Practice of Law. He served on the Professionalism Committee for the Virginia State Bar for four years and serves on the Third District Disciplinary Committee as Vice Chair of Section 2. Additionally, for over a decade, Mr. Crowgey held a position on the Board of Directors of the Community Tax Law Project, a nonprofit organization providing free tax services to indigent taxpayers throughout the Commonwealth of Virginia.

In addition to his legal experience, Mr. Crowgey is proud to be a citizen of the Commonwealth of Virginia and is passionate about using his knowledge and expertise to help further legislation that would create a more balanced playing field for Virginia’s taxpayers. In 2009 he was directly involved with the passage and implementation of legislation requiring the Virginia Department of Taxation to provide duplicate copies of all notices and communication sent to taxpayer’s to their counsel or accountant, similar to many other states as well as the IRS. In 2015 Mr. Crowgey, along with his associates Robert H. Johnson and Brockenbrough A. Lamb, were published in the Virginia Lawyer Register, and their article, “Everything Old is New Again: The Virginia Department of Taxation’s Attempts to Ignore the Limits of Collection,” caught the eye of state lawmakers. Subsequently, Mr. Crowgey was involved in assisting in the passage of HB 643, introduced by Del. James A. (“Jay”) Leftwich. This law requires a 7-year limitation period within which the Virginia Department of Taxation may collect outstanding income tax liabilities, thus providing even more protection for taxpayers in Virginia. Mr. Crowgey also taught as an Adjunct professor at the Virginia Commonwealth University School of Business, co-teaching a Master’s-level Accounting class in Tax Administration. Mr. Crowgey was featured in Virginia Business Magazine as part of their “Legal Elite” for 2016 and 2017, earning recognition for his outstanding work and experience in Taxation. Mr. Crowgey received the 2023 and 2024 Martindale-Hubbell Distinguished Attorney Award for achieving high ratings in both Legal Ability and Ethical Standing.

Court Admissions

Supreme Court of Virginia

United States Tax Court

United States Bankruptcy Court

United States District Court for the Eastern and Western Districts of Virginia

United States 4th Circuit Court of Appeals

Education

T.C. Williams School of Law at the University of Richmond, J.D.

Marshall-Wythe School of Law at the College of William and Mary, LL.M. (Taxation)

Reported Decisions

Coutlakis v. CSX Transp., Inc., No. 160277, 2017 Va. LEXIS 26 (Va. Mar. 9, 2017)

The Estate of Virgil R. May, M.D. v. Anthony Caruso, M.D. and Virginia Cardiovascular Associates, 264 Va. 358, 568 S.E. 2d 690 (2002).

Harrell v. Comm’r, T.C. Memo 2003-271, Reh’g Den., T.C. Memo 2003-312

Barnhill v. Commissioner, 155 T.C. 1 (2020)

Recent Tax Cases

Manson adv. United States of America (2022) –  United States District Court for the Eastern District of Virginia (Richmond), Case No.: 3:21-cv-419,  suit to reduce federal tax liens to judgment resulting in settlement and abatement by the government of 57% of the tax penalties and interest for over $500,000.00 of the trust fund civil penalties and dismissal of all federal tax liens after nearly 15 years of attempted enforcement by the IRS.

Compton v. United States of America—(2017) United States District Court for the District of Maryland (Baltimore), Civil Action No.: 1:17-cv-2032; represented taxpayer in refund claim regarding over $300,000.00 of converted trust fund civil penalty for past due employment taxes resulting in an agreed settlement with the United States Justice Department, Tax Division of the taxpayer paying back nearly one-third of the original proposed assessment over a period of years.

Elliot adv. United States of America.— (2013) United States District Court for the Eastern District of Virginia, Richmond Division, Criminal Action No. 3:13cr00085; represented local contractor in criminal tax investigation, resulting in a plea agreement to one count of criminal tax fraud.

In re: R. L— (2011); represented taxpayer accused of structuring over $450,000 in $100 bills resulting in client avoiding imprisonment through the Federal Pre-Trial Diversion Program. In 2016 the client was also approved for mitigation of forfeiture funds to be returned to the client in full by the Chief of the Criminal Investigation Division of the IRS.

In re: H. H— (2010); represented prominent Virginia Businessman who had an undisclosed bank account at UBS in Switzerland resulting in one of the first cases accepted under the United States Off Shore Account Amnesty Program.

Ellis et. al. adv. United States of America.— (2010) United States District Court for the Eastern District of Virginia, Richmond Division, Criminal Action No. 3:10cr00131; represented former NASCAR Busch Series champion charged in a criminal federal tax investigation, resulting in a plea agreement to one count of criminal tax fraud.

Virginia Department of Taxation v. A—I—L—M–(2008); compliance audit; sales tax assessment for $2.1 million, resulting in abatement of tax, penalties, and interest reducing the liability to $292,000 with an agreement to repay in 3 equal installments over 270 days.

Stanislas, et. al. adv. United States of America (2008) United States District Court for the Eastern District of Virginia, Richmond Division, Civil Action No. 3:07cv00393; federal tax lien case to foreclose over $800,000 in federal income taxes extending over 10 years against the taxpayers’ 4 properties in Petersburg, resulting in concession of over $300,000 in settlement of all issues between the Federal Government and the taxpayers voluntary sale of houses in complete release of any and all claims against the taxpayers.

Stallings, et. al. adv. United States of America, (2006) United States District Court for the District of South Carolina, Florence Division, Civil Action No.4:05cv03143; nominee liens filed against taxpayer for ex-husband’s $180,000+ income tax liability; dismissed with all tax liens being released on client’s property and the Internal Revenue Service paying client back over $23,000 in legal fees incurred.

Affiliations/Professional Memberships

Virginia State Bar – 1986

Virginia State Bar Council: 13th Judicial District 2008 – 2014

Virginia State Bar: Standing Committee on the Unauthorized Practice of Law, Vice-Chair 2012–2016

Virginia State Bar: Board of Governors, Taxation Section 2008–2015

The Community Tax Law Project 2008–2016, 2019-2023

Virginia State Bar Professionalism Committee 2018-2023

Third District Disciplinary Committee 2019-2025 Vice Chair (2023-2024)

Select Publications

Everything Old Is New Again: The Virginia Department of Taxation’s Attempt to Ignore the Limits of Collection; Virginia Lawyer Magazine | October 2015 | Vol. 64 | Taxation Section, pgs. 30-33

Tax Amnesty: Striking a Deal with Virginia’s Delinquent Taxpayers; Virginia Lawyer Magazine | October 2009 | Vol. 58 | No. 3 | pgs. 44-47

Robert H. “Bobby” Johnson was born and raised in Richmond, Virginia. He graduated from St. Christopher’s High School and received a Bachelor’s degree in Economics from the University of Virginia in 2007. In 2013, he received his Juris Doctorate from the T.C. Williams School of Law at the University of Richmond.

While attending the University of Richmond, Bobby concentrated his studies in taxation and commercial law. He served on several boards within the school, and in 2011 he founded the Richmond Council on Law and Economics. While serving with the policy department of former Virginia Governor Bob McDonnell, Bobby worked on identifying ways to improve the Virginia tax code.

In 2012, he worked with the in-house counsel for Southern States Cooperative dealing with a variety of corporate legal issues. While in law school he interned with the Chesterfield County Commonwealth’s Attorney’s office and tried several criminal cases.

Before completing his law degree, he also volunteered extensively with the Community Tax Law Project, a non-profit organization representing low-income taxpayers in matters involving the Internal Revenue Service and Virginia Department of Taxation. Bobby continues to support the organization.

In 2015, Bobby co-authored an article for Virginia Lawyer, “Everything Old is New Again: The Virginia Department of Taxation’s Attempts to Ignore the Limits of Collection,” which inspired legislation that was enacted by the Virginia General Assembly in 2016, creating a statute of limitations for the collection of delinquent taxes within the Commonwealth. Bobby has presented on tax topics including a Seminar for the National Business Institute, “Understanding Sale and Use Tax,” and participated on the panel, “Deciphering the New Tax Law.” ( See recording here)

The Tax Cuts and Jobs Act, enacted at the end of 2017, is the first substantial tax overhaul since the 1980s. Experts from the Richmond community joined faculty members Hayes Holderness and Danny Schaffa for an examination of the changes brought by the new tax law and a discussion of the major effects of those changes for taxpayers of all types.

Currently, Bobby is an associate with Crowgey & Associates and focuses his practice around state and federal tax controversy. He assists small business owners with a variety of tax and corporate issues. Bobby also sits on the board of the Tax Section of the Virginia Bar Association, is a class agent and fundraiser for St. Christopher’s High School.

When he is not practicing law, he spends most of his time racing as part of the crew of the J-109, Afterthought, and playing as a defender for the Central Virginia Soccer Association’s Die Macht F.C.

Court Admissions

Supreme Court of Virginia, 2013

United States Tax Court, 2014

Education

T.C. Williams School of Law at the University of Richmond, J.D., 2013

University of Virginia, B.A., Economics, 2007

Notable Tax Cases

Badias v. Virginia Department of Taxation, Circuit Court City of Richmond, CL 17003958-00

–     Settled $546,000sales tax assessment with the Virginia Department of Taxation for $26,500.

Cunningham v. Commissioner, Docket No. 27114-14

–     Reduced $22,215 IRS deficiency to $3,850 by proving retirement distribution was a qualifying rollover exempt from income tax.

 Price v. Commissioner, Docket No. 1267-16S

–     Completely exonerated taxpayer of $124,544 liability through application of the innocent spouse doctrine.

Ovalle v. Commissioner, Docket No. 18029-16

–     Removed $8,400 IRS deficiency by establishing income was erroneously attributed to taxpayer.

Reyes v. Commissioner, Docket No. 7113-17

–     Completely eliminated deficiency and secured refund of $3,325 by proving taxpayer properly claimed dependents.

Mohamed v. Commissioner, Docket No. 23951-16

–     Reduced tax liability and civil fraud penalty by $20,000.

Riley v. Commissioner, Dockett No. 13260-17 L

–     Challenge to Determination regarding Final Notice of Intent to Levy a taxpayer based on Trust Fund Civil Penalty assessment relating unpaid payroll taxes based on grounds that taxpayer never had a meaningful opportunity to challenge the assessment. Resulted in dismissal and no liability due from taxpayer.

Williams v. Commissioner, Docket No. 14265-18

–     Reversed $170,000 deficiency and associated penalties by establishing legitimacy of Schedule K-1 business losses.

Salinas v. Commissioner, Docket No. 13964-20

–     Reduced $10,000 audit assessment to $1,182 and removed all penalties

Kaponyi v. Commissioner, Docket No. 13982-21

–     Reduced capital gains deficiency and penalty of $130,000 to $737.

Gordon v. Commissioner, Docket No. 5669-21

–     Reduced deficiency and penalties assessed against owner of non-profit of $59,000 to $397.

Brown v. Commissioner, Dockett No. 27731-21

–     Established that taxpayer qualified for $58,700 mortgage interest deduction and that no tax was due on Notice of Deficiency.

Affiliations/Professional Memberships

Virginia State Bar, 2013

The Community Tax Law Project

Virginia Bar Association, Tax Section Board Member

Select Publications

Everything Old Is New Again: The Virginia Department of Taxation’s Attempt to Ignore the Limits of Collection ; Virginia Lawyer Magazine | October 2015 | Vol. 64 | Taxation Section, pgs. 30-33

Brockenbrough “Brokie” A. Lamb was born in Alexandria, Virginia and raised in Richmond, Virginia. He graduated from St. Christopher’s High School, and in 2000 received his Bachelor’s degree, graduating cum laude from Wake Forest University in Greek and English with Honors in Greek. In 2016 he received his law degree, graduating cum laude from T.C. Williams School of Law at the University of Richmond.

While attending the University of Richmond, Brockenbrough concentrated his studies in corporate, commercial and tax law. Brockenbrough was a Manuscript Editor at the University of Richmond Law Review, which, in the spring of 2015, selected his student comment for publication. During the summer of 2015, Brockenbrough worked as a clerk at Crowgey & Associates and co-authored an article for Virginia Lawyer, “Everything Old is New Again: The Virginia Department of Taxation’s Attempts to Ignore the Limits of Collection,” which inspired legislation that was enacted by the Virginia General Assembly in 2016, creating a statute of limitations for the collection of delinquent taxes within the Commonwealth.