Mrs. Michelle Abroms Levin

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.
  Represented regional government contractor in R&D tax credit audit at IRS Exam
  secured no-change agreement from IRS.
  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.
  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: 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)
  Lead counsel in 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 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)
  Lead counsel in 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)
  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)
  Lead counsel in USA v. Scott, Case No. 5:20-cr-00117 (N.D. Ala.) (secured probationary sentence for criminal defendant indicted for filing false tax returns)
  GlaxoSmithKline Holdings (Americas) Inc. v. Commissioner, U.S.Tax Court Docket Nos. 18940-08
  18941-08 (decision entered Oct. 4, 2010.) (Debt/equity, OID case fully conceded by IRS)
  Fidelity International Currency Advisor A Fund, L.L.C. v. United States, No. 05-40151 & 06-40130 (D. Mass.)
  Fidelity High Tech Advisor A Fund, L.L.C. v. United States, Nos. 06-4-243 & 06-40244 (D. Mass.) (45-day trial on variety of issues including economic substance, TEFRA
  tax treatment of contingent obligations)