People

Overview

Jon Feldhammer is the Partner-in-Charge of the firm’s San Francisco office and a former senior IRS trial attorney who now represents clients in high-stakes tax disputes. Most of his toughest cases are resolved quietly—often before litigation—so you won’t read about them. That is by design.

Jon understands how the IRS actually works—its priorities, pressure points, and decision-making process. He uses that insight to deescalate disputes, negotiate favorable resolutions, and, where appropriate, push the government to walk away. IRS personnel know him as both highly knowledgeable and a formidable advocate across every stage of a tax controversy, including examination, appeals, and litigation.

He has helped to resolve hundreds of complex matters involving the IRS, the California Franchise Tax Board, and other state agencies. His practice spans income tax, estate and gift tax, employment tax, and international tax issues.

Jon represents both individuals and public companies. Clients benefit from a hands-on, highly responsive approach combined with sophisticated technical judgment. He advises clients both proactively—helping them navigate new rules and correct past positions—and defensively, when disputes arise.

When necessary, Jon litigates in the U.S. Tax Court, U.S. District Court, and California Superior Court. But his focus is always the same: resolve the issue efficiently, protect the client’s interests, and avoid unnecessary exposure.

Admissions & Affiliations

  • State Bar of California
  • United States District Court for the Northern District of California
  • United States Tax Court
  • San Francisco Estate Planning Council, Member
  • American Bar Association, Taxation and Trust and Estate Law Sections, Member
  • California Bar Association, Taxation, Tax Litigation, and Trust and Estate Sections, Member
  • The Bar Association of San Francisco, Member

Education

  • J.D., Cardozo School of Law 2007
    Editor in Chief, Journal of International and Comparative Law
  • B.A., Vassar College 2000

Experience

  • Represented corporate and partnership clients before the IRS Exam and IRS Appeals involving section 48 investment tax credit (“ITC”) challenges with resolutions including no-changes and settlements at significantly reduced adjustments.
  • Negotiated favorable settlements for corporate clients with IRS Exam regarding meals provided to employees.
  • Successfully resolved partnership cases including disguised sales, at-risk rules, and disproportionate distributions.
  • Successfully resolved individual cases involving charitable deductions and assignment of income arguments before IRS Appeals.
  • Litigated estate and gift taxes issues including valuation, split-dollar arrangements, and family limited partnerships (“FLPs”).
  • Litigated FBAR penalties.
  • Litigated multiple cases involving bad debt and worthless securities.


Awards and Community

Selected as an "Outstanding Volunteer" by Justice & Diversity Center of the Bar Association of San Francisco (JDC), 2019-2023

Recognized in The Best Lawyers in America (Woodward White, Inc.) for Tax Litigation and Controversy, 2018-2023