TAX CONTROVERSIES AND LITIGATION

• Representation of clients before the United States Tax Court, the United States Court of Federal Claims, the United States District Courts and the United States Courts of Appeal;
• Member of the Tax Court and Court of Federal Claims Judicial Conferences;
• Representation of clients in tax audits and Appeals conferences before the IRS and state tax authorities;
• Representation of clients in state and local tax controversies;
• Representation of clients in tax collection matters, including the negotiation of offers in compromise and installment payment agreements.
• Representation of clients in innocent spouse appeals and litigation;
• Contesting the imposition of penalties; and
• Protection of taxpayers' rights.

DRAFTING

• Tax opinion letters;
• Tax portions of registered offerings filed with the Securities and Exchange Commission (SEC), including advising securities lawyers in connection with the structure of such transactions;
• Corporate and partnership documents;
• Employee-benefit and retirement plans, plan amendments and plan termination documentation and applications for determinations in connection with the plans;
• Applications for tax-exempt status for charities; and
• Wills, Trust Agreements, Powers of Attorney and Health Care Directives - including revocable and irrevocable trusts, life insurance trusts, "Crummey" trusts, "2503(c) trusts" for minors, unified credit shelter trusts, marital trusts, gift documentation, qualified terminable interest trusts (QTIPs), charitable lead and income trusts, qualified personal residence trusts, grantor retained annuity trusts (GRATs), grantor retained unitrusts (GRITs), qualified domestic trusts, and prenuptial agreements.

BUSINESS TRANSACTIONS

• Structuring complex corporate, partnership and exempt-organization business transactions, including mergers, acquisitions, reorganizations, sales to ESOPs, workouts and bankruptcies;
• Analysis of the tax aspects of financial transactions, including fraud; and
• Representation of clients in inventory-accounting issues in connection with securing certification of financial statements.

WEALTH TRANSFERS AND ESTATE PLANNING AND ADMINISTRATION

• Planning lifetime and deathtime gifts for clients, including charitable gifts and evaluations of the tax consequences of such gifts;
• Counseling clients as to how to transfer their property in an orderly and efficient manner while minimizing the payment of estate, gift and generation skipping transfer taxes;
• Preparation of Wills, trusts, powers of attorney and health care directives; and
• Estate probate and administration.

CHARITIES

• Representation of tax-exempt organizations and private foundations;
• Preparation and submission to the Internal Revenue Service of applications for tax-exempt status and requests for technical advice and private letter rulings.