Randall P. Andreozzi


Randall P. Andreozzi


Mr. Andreozzi’s legal career has focused on resolution of complex tax controversy matters, large case (corporate) tax matters, tax shelter litigation, employee welfare benefit litigation, and international/territorial tax issues.

For 16 years, Mr. Andreozzi worked for the IRS Office of Chief Counsel, where he served as Industry Counsel for the Commissioner’s Industry Specialization Program (ISP). He evaluated and litigated tax cases presenting Welfare Benefit Plan issues. Mr. Andreozzi litigated many seminal cases in this area, including General Signal Corp. v. Commissioner, Booth v. Commissioner, Parker Hannifin Corporation v. Commissioner, Square D Co. v. Commissioner and Neonatology Associates v. Commissioner. He also assisted and counseled other IRS attorneys and revenue agents in their development of cases under the ISP program, offering valuable expertise in areas involving tax shelters and the corporate income tax consequences of VEBAs and Welfare Benefit Plans.

During his years with the IRS Chief Counsel’s office, Mr. Andreozzi cultivated a strong reputation with attorneys and agents throughout IRS, as well as with outside tax practitioners nationwide. His extensive trial experience extends to other complex tax areas as well. Mr. Andreozzi tried a variety of complex precedential cases that have established important precedent in the areas of abusive tax shelters, corporate acquisitions (INDOPCO v. Commissioner), international taxation, United States Virgin Islands territorial taxation, and TEFRA partnerships.

Now in private practice with the firm of Andreozzi Bluestein LLP, Mr. Andreozzi continues to focus his practice on complex tax litigation and tax controversy resolution. His practice areas include international taxation and foreign bank account reporting, criminal tax and financial crime defense, employee benefit taxation, tax shelter litigation, and a variety emerging areas of federal and state tax law.

Mr. Andreozzi has published numerous articles on taxation, and frequently lectures on a variety of current and developing tax issues. He is an Adjunct Professor at the State University of New York (SUNY) at Buffalo School of Management, where he teaches Business Law at both the graduate and undergraduate levels. While he was with the IRS Office of Chief Counsel, he trained Chief Counsel trial attorneys at national litigation schools.

Awards and Honors

  • Office of Chief Counsel National Litigation Award (1997 and 2000)
  • Western Region Chief Counsel Litigation Trophy (1997)
  • Assistant Commissioner (Examination) Award (1995)

Academic Degrees

  • JD State University of New York at Buffalo
  • BA Canisius College English (Honors)
  • BA Canisius College Political Science

Licenses / Certification

  • New York State
  • United States Tax Court
  • United States Federal District Court,
  • Western District of New York