David Fuller focuses his practice on matters involving employee fringe benefits, independent contractor/employee classification, payroll taxes, information reporting, corporate aircraft, supplemental unemployment compensation benefits (SUB pay), and the contingent workforce (outsourcing, PEOs, and employee leasing). His unique practice includes tax litigation on a wide range of significant FICA and tax refund matters.

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  • Handled audits and appeals involving payroll tax and corporate deduction issues for companies in the health care, airline and technology industries where the proposed taxes and penalties, in the aggregate, totaled more than $350 million*
  • Led the IRS settlement negotiations for a large financial service entity in a customer and HR sensitive voluntary self-disclosure/self-correction matter before the IRS settling an issue of approximately $75 million for $2 million despite the fact the taxpayer had booked a reserve of more than $20 million*
  • 100% abatement of a $3 million stock option late deposit penalty involving a large corporate client’s next-day federal tax deposits*

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The Legal 500 US 2019


Anderson University, BA, 1980
University of Cincinnati College of Law, JD, 1983
New York University School of Law, LLM, 1984

District of Columbia

David Fuller

Insights & Events / Media

Chicago, IL / McDermott Event / May 8, 2019

Video / June 4, 2018