I am a partner in the Global Tax Group of Jones Day and have handled over 150 tax controversy and litigation cases against the IRS. I also assist U.S. taxpayers in their tax disputes around the world, which often raises tax and sensitive data privacy issues. Utilizing my tax law and economics background, I focus my practice on federal tax controversies & litigation on topics including transfer pricing and other valuation-based issues as well as the management and taxation of intellectual property. My cases involve all areas of tax law, including corporate income tax, employment tax, transfer pricing, ESOP, estate tax, and exempt organization tax issues. I have devoted my entire 20-year career to representing taxpayers, including Fortune 50 companies, estates, family offices, exempt organizations, and large privately-held businesses. I have handled tax litigation matters in the U.S. Tax Court, U.S. District Courts, and federal appellate courts around the country. As a tax litigator, I can handle all stages of a tax controversy, including all administrative and judicial levels from examination through court proceedings, as well as alternative dispute resolution avenues such as post-Appeals mediation. I firmly believe a tax litigator should be involved in any large-stakes tax controversy from the start of the IRS exam because inside the IRS is a large, well-trained law firm focused on the best interests of the IRS at all stages of tax disputes, and I like to offer taxpayers the same form of representation throughout a controversy. My broad tax controversy experience enables me to handle both the administrative proceedings and litigation with equal knowledge and proficiency and my economics background allows me to properly understand and challenge the findings of IRS economists. My extensive trial experience has confirmed that decisions made during an examination can significantly impact the chances of success at a future trial or the avoidance of trial.
Listed skills include Litigation, Tax Law, Appeals, Tax, and 22 others.