The founding of LeSourd & Patten in 1955 came out of a 100-day federal tax evasion trial in Seattle’s U.S. District Court in 1954. Fran LeSourd represented the defendant, who was acquitted, and Woolvin Patten served as the IRS special prosecutor. Each came away impressed by the other’s performance in a genuinely adversarial proceeding, and they became partners. Seven decades later, the firm they founded remains one of the leading tax law practices in the Pacific Northwest, rated first-tier in both Seattle Tax Law and Tax Litigation by Best Lawyers and US News Best Law Firms. The attorneys currently at the firm include veterans of the U.S. Department of Justice Tax Division and the IRS Office of Chief Counsel, who have brought the government’s approach to tax disputes to the private defense side.
Practice Areas
Civil Tax Controversy
The firm’s central practice is representing individuals and businesses in disputes with the IRS and the Washington State Department of Revenue. Civil tax controversy encompasses audits, administrative appeals, collection matters, and defense against IRS examinations and assessments. The firm’s attorneys negotiate with revenue agents and appeals officers, and take cases to the U.S. Tax Court when settlement is not achievable or appropriate. Robert McCallum has been selected to Super Lawyers in this area every year from 2000 to 2025. Sandra Veliz spent 13 years in the IRS Office of Chief Counsel, trying many cases before the Tax Court, before joining the firm.
Washington State Tax Controversy
In addition to federal tax disputes, the firm represents clients before the Washington State Department of Revenue in audits, appeals, and disputes over state business and occupation taxes, sales and use taxes, and related assessments. Washington’s tax structure presents issues that are distinct from federal tax law, and the firm handles both simultaneously for clients facing state and federal scrutiny.
Criminal Tax Defense
When the IRS refers a matter for criminal investigation, or when a grand jury targets a taxpayer for tax evasion, tax fraud, willful failure to file, or related charges, the stakes change categorically. The firm defends clients in criminal tax proceedings. Robert McCallum formerly served as a Trial Attorney in the U.S. Department of Justice Criminal Section, Tax Division, giving him direct experience with how these cases are built and prosecuted. Diane Tebelius is also a former DOJ Tax Division attorney. That prosecutorial background, brought to the defense, provides unusual insight into what the government must prove and how investigations proceed.
IRS Offshore Matters
Foreign financial accounts, offshore assets, and international tax compliance have been areas of intense IRS scrutiny. The firm handles FBAR (Foreign Bank Account Report) filings and delinquencies, offshore account disclosure through the IRS’s various voluntary disclosure programs, and defense in civil and criminal proceedings arising from international tax issues. Sandra Veliz specializes in IRS offshore matters in addition to civil tax controversy.
Business and Transactional Tax Planning
Beyond controversy work, the firm advises on the tax dimensions of business formations, acquisitions, sales, and restructurings. Tax planning at the transaction stage, whether structuring an LLC’s operating agreement or planning the tax treatment of a business sale, can determine economic outcomes that no subsequent controversy work can fully undo.
Gift and Estate Planning
The firm structures gifts, trusts, and estates to minimize federal and Washington State tax exposure. Richard Johnson’s LL.M. in Taxation from the University of Washington and P. Warren Marquardson’s work in gift and estate planning give this area depth that combines technical tax expertise with knowledge of trust and estate law.
Probate and Trusts
Trust administration and probate matters are handled alongside the firm’s tax work, with particular attention to the tax dimensions of estate administration.
Bankruptcy Tax Matters
Tax claims in bankruptcy present specialized issues: the dischargeability of tax debts, the treatment of the IRS as a creditor, and compliance obligations during and after bankruptcy proceedings. Diane Tebelius specializes in bankruptcy tax matters in addition to civil tax controversy.
Attorney Profiles
Richard L. Johnson joined the firm in 2006, the same year he earned his J.D. cum laude from Seattle University School of Law. He subsequently earned an LL.M. in Taxation from the University of Washington School of Law in 2009. He holds a B.A. in Economics and Chemistry-Biology from Whitman College. He is admitted to the Washington State Bar, the U.S. Tax Court, the U.S. District Court for the Western District of Washington, and the U.S. Court of Appeals for the Ninth Circuit. He teaches federal tax procedure at the UW Foster School of Business. Within the Washington State Bar Association’s Taxation Section, he has served as Communications Chair and was Chair from 2018 to 2019. He has been selected to Best Lawyers in America from 2010 to 2023 and to Super Lawyers from 2018 to 2023, and was a Super Lawyers Rising Star from 2011 to 2016.
P. Warren Marquardson practices gift and estate planning, probate and trusts, and business and transactional tax planning. Detailed educational and bar admission information is not publicly available.
Robert M. McCallum is a Partner who holds a B.A. from Middlebury College (1974), a J.D. from California Western School of Law, and an LL.M. in Taxation. He was admitted to the Minnesota Bar in 1978 and the Washington Bar in 1986. From 1980 to 1982, he served as an Attorney-Advisor at the U.S. Tax Court. From 1982 to 1986, he was a Trial Attorney in the U.S. Department of Justice Criminal Section, Tax Division. His practice covers civil and criminal tax litigation, pension and profit sharing, real estate, environmental, and business litigation. He formerly taught at the Graduate School of Taxation at Golden Gate University, where he received the Outstanding Faculty Award in 1992. He has been selected to Super Lawyers every year from 2000 to 2025.
Diane E. Tebelius is an attorney who formerly served in the Department of Justice Tax Division. She specializes in civil tax controversy and bankruptcy tax matters. She has been selected to the Super Lawyers list. Specific educational and bar admission details are not publicly available.
Sandra Veliz is an attorney who spent 13 years in the IRS Office of Chief Counsel, where she tried numerous cases before the U.S. Tax Court. She specializes in civil tax controversy, criminal tax defense, and IRS offshore matters. She has been selected to the Super Lawyers or Rising Stars list. Specific educational details are not publicly available.
Location and Service Area
20 Sixth Ave NE, Issaquah, WA 98027
Phone: (206) 624-1040
Email: [email protected]
Website: https://lesourd.com/
The firm serves clients in Issaquah, the Seattle metropolitan area, and throughout Washington State. Federal tax matters are handled nationally.
Client Approach
The firm has operated for 70 years on the premise that tax disputes require attorneys who understand how the government builds its cases. The current roster includes attorneys from both the DOJ Tax Division and the IRS Chief Counsel’s office, positions from which they prosecuted and litigated the very types of matters they now defend. The firm emphasizes close client relationships and describes its billing as fair and reasonable.
Frequently Asked Questions
How did the 1954 trial in Seattle’s federal court lead to the founding of the firm?
Fran LeSourd and Woolvin Patten were on opposite sides of a 100-day federal tax evasion trial in Seattle. LeSourd represented the defendant (who was acquitted) and Patten was the IRS special prosecutor. Having seen each other perform under sustained adversarial conditions over months of trial, they decided to become partners. They founded the firm in 1955.
What is the significance of having former DOJ Tax Division and IRS Chief Counsel attorneys on staff?
Attorneys who prosecuted tax cases for the government understand how audits escalate into criminal referrals, how the IRS constructs fraud cases, and what evidence the government needs to proceed. That perspective, applied to the defense, provides insight into where the government’s case is strong and where it is vulnerable. It also allows the firm to anticipate government strategy rather than simply react to it.
What does Robert McCallum’s consecutive Super Lawyers recognition from 2000 to 2025 indicate?
Super Lawyers selects attorneys through a multi-step process involving peer nominations, independent research, and peer evaluations. A 25-year consecutive run on the list reflects consistent peer recognition over a long career, not a single notable moment.
What is the difference between civil tax controversy and criminal tax defense?
Civil tax controversy involves disagreements over the amount of tax owed, penalties, and collection. The consequences are financial: additional taxes, penalties, and interest. Criminal tax cases involve allegations of willful conduct, tax fraud, or evasion, and carry potential imprisonment in addition to financial penalties. The standard of proof, the procedures, and the potential consequences are fundamentally different.
Does the firm handle both federal and Washington State tax disputes?
Yes. The firm represents clients before the IRS, the U.S. Tax Court, and federal appellate courts for federal matters, and before the Washington State Department of Revenue for state tax disputes. Many business tax audits involve both federal and state issues simultaneously.