Mr. Ronald Alan Levitt

Practice Details

• Firm Information
  Position

  Shareholder

  Firm Name

  Dentons Sirote PC
• Representative Cases & Transactions
  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 bad debt deduction audit through IRS mediation program.
  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)
  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)
  Dabney v. United States, Civil Action No. 1:18-cv-00483 (S.D. Ala) (Refund suit involving gain from disposition of shares treated as shareholder compensation, obtained significant concession from DOJ prior to trial)
  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)
  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)
  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)