Eli S. Noff
Chair, Tax Controversy
Location:
Annapolis Office
Phone: 202-618-1873
Fax: 888-235-8405
Email: Contact Us
Eli utilizes his background as a CPA and attorney to vigorously defend clients before the IRS and state taxing authorities. Eli is also the firm’s lead on international tax matters, which involves complex international tax compliance issues, resolving many offshore voluntary disclosures and streamlined filing compliance procedures, as well as preparing complex Passive Foreign Investment Company (PFIC) computations. He also represents clients in a significant number of tax collection matters, federal and state examinations and appeals, IRS criminal investigations, and matters before the federal and state tax courts.
Eli has been a part of Frost Law since it began. His tireless efforts in all aspects of the firm’s practice have been instrumental in fueling the firm’s success and growth.
Eli was a Legal Extern at the Internal Revenue Service Office of Chief Counsel, where he conducted legal research, analyzed cases for potential strengths and weaknesses, participated in settlement conferences, drafted proposed factual stipulations to comply with court rules, and drafted several pleadings and motions.
Eli also managed a team of accountants at the Baltimore Creating Assets Savings and Hope Campaign, a non-profit tax preparation organization, where he prepared income tax returns for moderate-income families, provided tax expertise to tax preparers, ensured quality review, and maintained the site in accordance with IRS regulations. Under Eli’s supervision, his team was awarded the Quality Tax Preparer Award for the lowest number of organization-wide rejected returns.
Eli is a graduate of the University of Maryland School of Law where he received his Juris Doctor with honors. Eli is an active member of the American Bar Association and the Maryland State Bar Association. He is admitted to practice law in the State of Maryland and is a licensed Maryland CPA. He has also been recognized by Super Lawyers as a Rising Star.
Eli is a husband and father of four and enjoys traveling and spending time with his family. His ultimate goal at Frost Law is to utilize his analytical skills to quickly and proficiently identify problems within tax cases and solve problems favorably for his clients.
Bar Admissions
- District of Columbia
- Maryland
- United States District Court of the District of Maryland
- United States Tax Court
- Federal Court of Claims
Professional Associations and Memberships
- Maryland State Bar Association
- Chair of the American Bar Association Committee on Tax Collection, Bankruptcy, and Workouts (incoming Chair Spring 2021)
- Chair of the American Citizens Abroad Israel Chapter
- Associate member of Maryland State Bar Association Tax Section
- Anne Arundel Bar Association
- Member of the Collection Due Process Initiative
- Maryland Volunteer Legal Services Mentorship Program
- The Fellows of American Bar Foundation
Education
- University of Maryland School of Law, Baltimore, Maryland
- J.D. cum laude
- Ner Israel Rabbinical College
- Bachelor of Talmudic Law
- University of Memphis
- Certified Public Accountant, Maryland
Awards and Honors
- SUPER LAWYERS RISING STARS: 2015 – 2021
- Top Lawyers of Maryland 2020
Published Works
- What’s Reasonable For Late-Filed Foreign Information Tax Returns?
- Certain U.S. Individuals Exempted from Tax-Favored Foreign Trust Information Reporting
- IRS Can Re-litigate Tax Liability in Civil Court After it was Previously Resolved in a Criminal Proceeding
- Execution of Closing Agreement for Tax Return Preparer Penalties Waived Supervisory Approval Requirement
- Proposed Regulations Clarify Tax Treatment of Charitable Donations in Return for SALT Credits
- QBI Guidance Issued; Safe Harbor Provided for Real Estate Enterprises
- Form 4340 is Sufficient Corroborating Evidence Proving Issuance of Notice of Deficiency
- The Foreign Account Tax Compliance Act: What is FATCA?
- Innocent Spouse Relief (IRC §6015)
- Time Travelling with the Section 962 Election
- United States v. Garrity: Clarifies Standard of Proof and Establishing Willfulness in FBAR Context
- Virtual and Economic Contacts Establish Nexus for Sales Tax
- Coming Out of the Dark of International Tax Avoidance
- Updated Guidance for IRS Voluntary Disclosure Practice
- The QBI Deduction for Real Estate Businesses
- IRS Actively Targeting Taxpayers For Passport Denial/Revocation
- What’s Your Alien Tax Status and How Does it Affect Investment Property?
- I.R.C. §280E: A Buzzkill for Those who Keep Poor Records
- Wesley Snipes Makes Offer the IRS can Refuse
- Untimely CDP Arguments Worth Consideration
- End of Offshore Voluntary Disclosure Program Imminent
- District Court Maintains $100,000 Regulatory Cap for Willful FBAR Violations
- Maximize Your Benefits Under the 2019 Maryland Student Debt Relief Tax Credit
- IRS Indicates Intent to Actively Pursue Passport Revocations
- Court Orders IRS to Amend Overbroad Summons for Cryptocurrency Information
- Psychic Never Saw it Coming: IRS Recharacterizes Loan as Income
- 401(k) Distribution for First Home Purchase Included in Income and Subject to Penalty
- Are Virtual Currencies Held in Foreign Exchanges FBAR Reportable?
- Government Charges Former CPA with Filing False Streamlined Offshore Submission
- New IRS Procedures Offer Significant Relief for Certain Expatriates
- The Dispute Over Non-Willful FBAR Violation Calculations
- IRS Finalizes Safe Harbor for Rental Real Estate Enterprise to Qualify as Business for QBI Deduction
- IRS Must Provide Taxpayer a Chance to Cure Offer in Compromise Default
- “Fatally Inconsistent:” Notice of Deficiency Invalid Due to Ambiguity
- Expanding “Gig Economy” Redefining Employee Classification
- Proposed Tax Levy Sustained to Collect from Non-Compliant Former Harvard Professor
- BP Deepwater Horizon Case Proceeds After Tax Court Reviews IRS Handling of Whistleblower’s Claim
- How Does the New Act’s Key Tax Extenders Potentially Impact Your Individual and Business Returns?
- Must the IRS Obtain Supervisory Approval Before Assessing You with Personal Responsibility for Employment Taxes (TFRP)?
- No Evidentiary Burden for IRS Applicable to Accrued Interest and Penalties
- Rapidly Approaching BE-10 Survey Deadlines to Report Your Foreign Investments
- Proposed Regs Maintain Deductibility of Business Meals
- IRS Reverses Temporary TAS Passport Program Relief
- Significant Changes to PPP Loan Forgiveness Via the New PPP Flexibility Act
- Another Court Finds FBAR Penalties Survive Non-Filer’s Death
- Comptroller Issues Guidance Regarding Employer Withholding Requirements for Teleworkers During Pandemic
- Updated Guidance Preserves PPP Loan Forgiveness When Employees Decline Rehire Offer
- PPP Loan Forgiveness is Not Allowed to Result in Double-Dipping
- What Employers Must Know to Maximize PPP Loan Forgiveness
- IRS Reversal of ‘Serious Delinquent Tax Debt’ Certification Renders Case Moot in Tax Court
- U.S. District Court Breaks with Sister Court, Deciding Non-Willful FBAR Penalty is by Form, Not Account
- Renowned Tony Luke’s Face Charges of Conspiracy and Tax Evasion
Speaking Engagements
MSATP Events
- Assisting Individuals & Small Businesses with Significant Tax Debts in IRS Collections
- International Tax Compliance: How to Disclose Foreign Bank Accounts
- Payroll Tax and Personal Liability — What You Need to Know!
- PPP Loan Forgiveness After Passage of the PPP Flexibility Act of 2020
- IRS Domestic Voluntary Disclosure Guidance – How to Bring a Non-Compliant Client into Compliance
- PPP Forgiveness Update: The Latest SBA Forgiveness Application, Instructions and Guidance
- CPE Dinner Series – Managing Spouses Joint & Several Tax Liabilities
- Settling Tax Debt When Bankruptcy May Be A Better Option
- How to Represent Your Clients in the IRS and State Collection Process
MACPA Events
- Handling IRS Examinations of Individuals and Small Business Taxpayers
- International Tax Compliance – How to Disclose Foreign Bank Accounts
- Assisting Individuals and Small Businesses with Significant Tax Debts in IRS Collections
MSBA Events
- The Paycheck Protection Program and Important CARES Act Benefits to Help You and Your Clients
- 2016 Annual Meeting on Offshore Account Compliance
ABA National Panels
- Updates on IRS Enforcement Post-COVID
- Civil and Criminal Tax Conference
- 2019 May Tax Meeting – Current Enforcement Priorities in IRS Collection
- 2019 Midyear Tax Meeting Featured Panelist
The “Money, Riches & Wealth” Podcast on TalkRadio 680 WCBM
- PPP Loan Forgiveness, June 24, 2020
- PPP Forgiveness Guidance, May 27, 2020
- Tax Controversy and Enforcement Issues, September 4, 2019
- International Tax, September 5, 2018
The Goldstein on Gelt Show
Features
- Maryland Bar Journal
- The Free State Accountant Winter 2021 Edition
- What’s Reasonable for Late-Filed Foreign Information Returns?
Languages
- Hebrew
- English
