Steven Gremminger is the principal and owner of the Gremminger Law firm. He has almost 35 years of experience in all aspects of civil litigation, including every type of tax litigation, tax and accounting malpractice, and SEC matters. Steve has also represented clients in a variety of white collar matters involving tax as well as other issues. He is an expert at evaluating complex accounting and tax malpractice matters. Possibly, his best work may involve the evaluation, negotiation, and settlement of claims.
Steve served thirteen years at the United States Department of Justice, Tax Division. While there, he earned three Outstanding Attorney awards, as well as a Special Commendation from Attorney General Griffin Bell. Steve became a Tax Division Senior Trial Attorney sooner than any other attorney in the history of the Tax Division. He regularly trained entry level attorneys on trial practice, advocacy and other matters. During his last four years with the Tax Division he was a Reviewer. He regularly reviewed the written work of twenty five attorneys. During this time, he also sponsored a very popular internal seminar entitled "Dealing with SOBs in Litigation."
During Steve's DOJ career, he litigated against drug dealers and arms smugglers, with individuals, corporations and even against the Ku Klux Klan. He was the lead trial attorney for DOJ trials involving virtually every kind of civil tax matter, from complex refund matters to liens, levies, jeopardy assessments, and summonses. His refund cases included very complicated suits involving issues such as stock options, oil and gas, the valuation of bottling and other companies, estate and gift, the constitutionality of retroactive federal tax regulations, and many other topics.
Steve's career accomplishments include:
- Steve was both a Principal (Partner) as well as an Associate General Counsel of KPMG, LLP for 11 years. He was the principal legal advisor for KPMG's nationwide tax practice — the firm had more than 1,100 partners and more than 20,000 employees in the United States at that time. Steve was responsible for all of the tax related civil litigation against KPMG, as well as the regulatory aspects of the tax practice, including the federal civil tax investigation.
- There were more than 250 civil suits against KPMG and more than 200 matters were settled. He participated in over 100 mediations. During his last year, he administered a $500 million budget.
- Steve also engineered a major class action involving more than 100 KPMG tax clients on KPMG's behalf.
- He defended several suits involving the KPMG audit practice, with outstanding results — including in one case the complete dismissal of all charges.
- Steve was instrumental in advising both the KPMG tax and audit practices regarding independence and litigation, issues, legal issues of all sorts, and other matters.
- Steve was the Assistant General Counsel at Ernst & Young LLP, and successfully defended a suit by the SEC trying to take away the licenses of two E&Y auditors. See In the Matter of Angelo P. Danna, CPA and Mark P. Dentinger, CPA, Exchange Act of 1934, Accounting and Auditing Enforcement Act, Release No. 907, 38499, 34-38499, AE-907, 64 SEC Docket 720, 1997 WL 197555 (April 14, 1997). .
- Steve was the lead DOJ attorney in over 250 cases. The cases include C.M. Thibodeaux v. U.S., (915 F.2d 992 (1990)). This oil and gas case involved the question of the federal taxation of delay rentals and lease bonus payments. Steve argued the case before the U.S. District Court, which ruled in the Government’s favor. Summary judgment was granted after oral argument, and the US Court of Appeals for the Fifth Circuit thereafter affirmed.
- Steve was the lead DOJ attorney in the case of Carol Camp, as Administratix of the Estate of Alder B. Seal, Deceased v. Commissioner of the Internal Revenue Service and United States of America (635 F.Supp. 585 (1986)) This case involved a $29.7 million jeopardy assessment against Mr. Seal, who was a very notorious drug smuggler who later became even more prominent during the Iran-Contra matter because of his links to the CIA, DEA, and the White House. Mr. Seal was killed by Colombian hit men prior to the trial. The national media covered the case. There is an HBO movie about Mr. Seal with a handsome actor portraying Steve.
- Steve was the lead DOJ attorney in the case of Century Hotels v. United States (952 F. 2d 107 (1992). The case, heard in the US Court of Appeals, Fifth Circuit. This case involved a very prominent New Orleans resident, who owed a lot of money to the IRS yet had the lifestyle of the "rich and famous." Steve met and subpoenaed many if not all of the New Orleans restaurateurs in connection with this case — as a result he is a talented judge of New Orleans cuisine!
- Steve was the sole DOJ attorney in the case of the Estate of Norman L. Johnson v. United States of America (836 F.2d 940). In fact, this case was one of many in a series of cases involving Mr. Johnson, who was a prominent New Orleans personage who substantially underreported his income. Steve successfully defended a jeopardy assessment, a levy action (involving world class art work), several foreclosure actions, and levies against both jewelry as well as the entire contents of the Johnson residence.
- Steve successfully negotiated with a Middle-Eastern Government regarding a tax matter. Steve is currently representing clients in complex litigation before the United States Tax Court involving oil and gas partnerships; penalties; and an innocent spouse case. He also is representing a number of individuals and companies who are being audited by the IRS, including persons against whom the IRS has asserted fraud.
Steve has frequent speaking engagements, at professional conferences and to private groups as well as at universities. He was recently a member of a panel at the University of Florida Levin School of Law Graduate Tax Program. The panel included a United States District Judge, and the topic was "It's Dangerous to be Right when the Government is Wrong."
In July, he spoke at the CBIZ MHM annual conference on the topic of prosecutorial misconduct, in a presentation entitled "How the KPMG Shelters Became Criminal."