Courtney A. Hopley

Courtney A. Hopley: Attorney with Greenberg Traurig, LLP

Biography

Courtney A. Hopley represents clients in federal and state tax controversies before the IRS and the California Franchise Tax Board at the audit, collection, appeals and litigation stages. She works on tax controversy matters involving partnerships, corporations, individuals, real estate and penalty disputes. Courtney also has experience in tax planning involving entity formation, mergers and acquisitions, and reorganization transactions.

Concentrations

• Civil tax controversies
• Tax compliance advice
• Tax shelter investigations, audit and litigation
• Tax penalties

Recognition & Leadership

Awards & Accolades

• Team Member, a Law360 'Real Estate Practice Group of the Year,' 2023
• Listed, The Legal 500 United States, US Taxes: Contentious, 2021
• Listed, Super Lawyers magazine, Northern California Super Lawyers, 'Rising Stars,' 2013-2020

See more ›

Areas of Practice (9)

  • Tax
  • Tax Controversy and Litigation
  • State & Local Tax (SALT)
  • Real Estate Tax
  • Cross-Border Tax Planning
  • Private Wealth Services
  • State & Federal Tax Controversies
  • Equine Industry Group
  • Real Estate

Education & Credentials

University Attended:
Colorado College, B.A., Phi Beta Kappa, 2003
Law School Attended:
University of Colorado Law School, J.D., 2006; New York University School of Law, LL.M., Taxation, 2007
Year of First Admission:
2006
Admission:
2006, Colorado; 2009, California; U.S. Tax Court
Memberships:

Professional & Community Involvement

•fellow, American College of Tax Counsel, 2025-Present
•Member, American Bar Association, Taxation Section
•Member, California State Bar, Taxation Section
•Member, Executive Committee, 2016-Present
•Chair, Tax Procedure & Litigation Subcommittee, 2015-2016
•Member, San Francisco Tax Club

Birth Information:
Denver, Colorado, 1980
Reported Cases:
Experience: Civil Tax Audit and Litigation Representative Experience: Represented group of related taxpayers in case involving complex partnership transaction.; Successfully defended multiple taxpayers in residency matters involving the California Franchise Tax Board.; Defended taxpayer in civil forfeiture action involving inadvertent violation of the structuring rules.; Tax Compliance Advice Representative Experience: Drafted Private Letter Ruling Request involving late I.R.C. Section 663(b) election.; Assist taxpayers in residency planning.; Advised financial institution regarding penalty exposure for in-house tax return preparation activities.; Advised family office regarding procedures for protecting attorney-client privilege.; Drafted tax opinions regarding various tax issues.; Tax Penalties Representative Experience: Represented taxpayers in tax audits involving FBAR and other international tax penalties.; Obtained penalty abatements involving accuracy, delinquency, trust fund recovery, employment tax penalties.
ISLN:
919550771

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Location

Contact Courtney A. Hopley

Contact Information:

415-358-4970  Fax

www.gtlaw.com/People/HopleyCourtneyA

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