Craig A. Houghton

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Craig A. Houghton


Mr. Houghton joined the Business Transactions Practice Group at McCormick Barstow LLP in 2024. He is the Chair of the firm’s Tax Planning and Tax Controversies Practice. Prior to that, he was a shareholder with Baker Manock & Jensen, PC.

For over 44 years, Mr. Houghton has represented and advised clients regarding sophisticated tax planning and transactions, in tax controversies before the Internal Revenue Service, State and local tax agencies, and the United States Tax Court, the Federal District Courts and Courts of Appeals, and the State Courts, and with tax compliance. Clients include corporations, partnerships, limited liability companies, cooperatives, individuals, trusts, and estates. He has also developed an expertise in representing and advising Indian Tribes, tribal entities, and tribal members on Federal, State, and local tax matters. He is AV Preeminent ® rated by Martindale-Hubbell.

Mr. Houghton is admitted to practice in California.

LL.M., Taxation, 1982                                                           
New York University School of Law

Juris Doctor, 1979                                                           
Hastings College of Law University of California

Bachelor of Arts, 1976, highest honors                                                               
University of California San Diego


Mergers and Acquisitions
Asset Sales, Stock Sales, and Bootstrap Acquisitions
Entity Formations, Restructuring, and Reorganizations
Basis, At Risk, and Passive Loss Tax Planning
Insolvency and Workout Tax Planning
Affiliated Entity and Transfer Pricing Tax Planning
Succession Planning (including Entity and Asset Valuation Issues)
Sales, Use, and Other Business Taxes Planning
Property Tax Planning


Income, Estate and Gift, Employment, Sales and Use, and other Business Tax Audits
California Residency Audits (Individuals and Tribal Members)
Penalty Abatement or Waiver Claims (including Offshore)
Tax Administrative Appeals (Federal and California)
Tax Collection Issues (including Tax Liens, Levies, and Collection Due Process Appeals)
Deficiency and Collection Cases in the United States Tax Court
Tax Refund Suits in the Federal District Courts
Tax Appeals in the Federal Courts of Appeals
Property Tax Appeals


Tax Reporting Issues (including Disclosure Issues)
Amended Returns and Claims for Refund
Accounting Method Issues
Non-Filed and Delinquent Return Issues
Federal Voluntary Disclosures (Domestic and Offshore)

Bar Admissions

– State Bar of California
– United States Tax Court
– U.S. District Courts (Eastern and Central Districts of California)
– United States Court of Appeals (Ninth and Eight Circuits)
– Supreme Court of the United States
– U.S. Court of Federal Claims

American Bar Association

-Section of Taxation, Member Various Committees
Chair former Business Cooperatives & Agriculture Committee

California Lawyers Association

– Tax Section, Member Various Committees
Executive Committee Member and Vice Chair (1998-2001)

Federal Bar Association

-San Joaquin Valley Chapter Secretary and Board Member (Former President)
-Chair/Coordinator Tax Court Pro Se Program (2011-Present)

National Conference of Commissioners on Uniform State Laws Limited Cooperative Associations Act

-ABA Advisor to Drafting Committee

Fresno County Bar Association

Honors & Awards

Mr. Houghton is AV® Preeminent™ Peer Review Rated with Martindale-Hubbell.

Cases of Significant Interst

Peracchi v. Commissioner of Internal Revenue, 143 F.3d 487 (9th Cir. 1998)
Rojas v. Commissioner of Internal Revenue, 901 F.2d 810 (9th Cir. 1990)
Agro-Jal Farming Enterprises, Inc. v. Commissioner of Internal Revenue, 145 T.C. 145 (2015)

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