Cases
Representative Matters: Pre-litigation: Successfully settled several conservation easements audits at IRS Exam or IRS Appeals for 50%-80% of the amount claimed on the return
secured waiver of penalties.
Successfully settled complex income reporting issue for pharmaceutical company at IRS Appeals Office, resulting in complete relief from IRS liability.
Successfully settled bad debt deduction audit through IRS mediation program.
Represented multiple individuals in the Offshore Voluntary Disclosure Program ( OVDP )
alternative Streamline Disclosure Program.
Secured installment agreement for taxpayer with over $2 million in unpaid taxes.
Successfully negotiated offers in compromise on behalf of taxpayers with wide-ranging tax liabilities.
Successfully resolved numerous family limited partnership ( FLP ) discounted cases with IRS appeals office
IRS trial attorneys.
Full IRS concession on proposed passive activity loss (I.R.C. 469) adjustments in IRS Appeals
at U.S. Tax Court on behalf of high net-worth individuals.
Complex Litigation: Kiva Dunes v. Commissioner, T.C. Memo. 2009-145 (June 22, 2009) (Successfully defended $28 Million conservation easement deduction on golf course)
Pine Mountain Preserve, LLLP v. Commissioner, 978 F.3d 1200 (11th Cir. 2020)(Eleventh Circuit decision in favor of taxpayer
overturning Tax Court decision disallowing charitable deduction for two conservation easement donations)
Lead counsel in Rajagopalan v. Commissioner, T.C. Memo. 2020-159 (Nov. 19, 2020)(Tax Court victory in conservation easement case involving NFL star where IRS contested value
deductions claimed for $4.5 million charitable donation)
Dickerson v. Comm'r, 2012 T.C. Memo 2012-60 (March 6, 2012) (successfully argued the application of a discounted to the value of a $2.4 million lottery ticket to account for contingent claims, resulting in estate tax relief)
Hewitt v. Commissioner, T.C. Memo 2020-89 (June 17, 2020) (on appeal to the Eleventh Circuit) (favorable Tax Court decision in conservation easement case on value
penalties)
Lead counsel in Glade Creek Partners, v. Commissioner, T.C. Memo 2020-148 (Nov. 2, 2020) (favorable Tax Court decision in conservation easement case on value
penalties)
Oakbrook L
Holdings, LLC v. Commissioner, 154 T.C. No. 10 (2020) (on appeal to the Sixth Circuit) (seminal Tax Court case concerning validity of Qualified Conservation Contribution regulations resulting split Tax Court opinion)
Lead counsel in Belair Woods v. Commissioner, 154 T.C. No. 1 (2020) (seminal Tax Court case concerning IRS obligations under IRC 6751 in asserting penalties
split Tax Court opinion)
Lead counsel in Goldring v. United States, Civil Action No. 18-10756 (E.D. La.) (complex refund litigation concerning character of litigation proceeds in stockholder dispute
underpayment interest)
PBBM-Rose Hill, Ltd. v. Comm'r, 900 F.3d 193 (5th Cir. 2018)(argued case in 5th Circuit reversing Tax Court on issue of whether conservation easement on golf course satisfied conservation purpose)
