Active tax controversy legal practice dealing with local, state and federal audits, criminal investigations, IRS collections, and civil and criminal tax litigation in Arizona courts, the United States Tax Court and Federal District Court and appeals.Representative Cases:Gardner v. Commissioner, T.C. Memo. 2013-67 Storey v. Commissioner, T.C. Memo. 2013-59 Trainor v. Commissioner, T.C. Memo. 2013-14F-Star Property Management, Inc. v. Commissioner, T.C. Memo… Show more Active tax controversy legal practice dealing with local, state and federal audits, criminal investigations, IRS collections, and civil and criminal tax litigation in Arizona courts, the United States Tax Court and Federal District Court and appeals.Representative Cases:Gardner v. Commissioner, T.C. Memo. 2013-67 Storey v. Commissioner, T.C. Memo. 2013-59 Trainor v. Commissioner, T.C. Memo. 2013-14F-Star Property Management, Inc. v. Commissioner, T.C. Memo. 2013-6Storey v. Commissioner, T.C. Memo. 2012-115Estate of Foster v. Commissioner, T.C. Memo. 2011-95Conway, et al. v. Commissioner, 137 T.C. No. 16 (2011) Klebanoff v. Commissioner, T.C. Summary Opinion 2011-46Colvin v. Commissioner, T.C. Memo. 2010-235Bigley v. Commissioner, T.C. Memo. 2010-29Perkins v. Commissioner, T.C. Memo. 2008-261Klootwyk v. Commissioner, T.C. Memo. 2008-214Nicholas v. Commissioner, T.C. Summary Opinion 2008-155Kee v. Commissioner, T.C. Summary Opinion 2008-150Perkins v. Commissioner, T.C. Memo. 2008-103Smith v. Commissioner, T.C. Memo. 2007-368 Koskella v. Commissioner, T.C. Summary Opinion 2005-122Krohn v. Commissioner, T.C. Summary Opinion 2005-145Classes/Seminars:• Presenter: IRS Collections–How to Resolve Problems, Dallas CPA Society Convergence, 2013• Presenter: IRS Chief Counsel Lecture Series – An Overview of Civil Fraud, 2013• Presenter: Boot Camp, The Mock Trial, Tax Alliance Conference, 2012Honors and Awards:• IRS Lucite Litigation Award, 2011• IRS Litigation Excellence Medallion, 2010• IRS Trial Team of the Year Award, 2007 Show less

• Provided technical guidance and supervisory oversight of all litigation and advisory activities performed by trial practice group, which includes representing the IRS in the U.S. Tax Court and local bankruptcy courts, provide advice and assistance to IRS officials concerning assessment, collection and protection of taxes, and assisting the U.S. Attorney’s Office and Department of Justice (Tax Division) in any civil proceeding.• Served as the primary advisor to the Area Counsel on all… Show more • Provided technical guidance and supervisory oversight of all litigation and advisory activities performed by trial practice group, which includes representing the IRS in the U.S. Tax Court and local bankruptcy courts, provide advice and assistance to IRS officials concerning assessment, collection and protection of taxes, and assisting the U.S. Attorney’s Office and Department of Justice (Tax Division) in any civil proceeding.• Served as the primary advisor to the Area Counsel on all management and legal matters within the trial practice group’s jurisdiction.• Provided internal and external training, including external speaking presentations regarding IRS practice and procedure.• Acted as a liaison between the Office of Chief Counsel and IRS Appeals, Exam and Collection for issues and cases under the trial group’s jurisdiction.• Reviewed and coordinate assignments and priorities in coordination with Area Counsel objectives and directives.• Supervised attorneys and paralegal support staff engaged in providing litigation support to the IRS. Show less

• Conducted all aspects of significant case management, trial preparation and litigation, including: witness interview and examination, expert witness procurement and preparation, analysis of law and hazards of litigation, and presentation or litigation of government’s case in IRS Appeals and the U.S. Tax Court.• Provided technical and legal support in Appeals Mediation and Fast Track. • Provided formal and informal advice and case development assistance to Appeals Officers, Revenue… Show more • Conducted all aspects of significant case management, trial preparation and litigation, including: witness interview and examination, expert witness procurement and preparation, analysis of law and hazards of litigation, and presentation or litigation of government’s case in IRS Appeals and the U.S. Tax Court.• Provided technical and legal support in Appeals Mediation and Fast Track. • Provided formal and informal advice and case development assistance to Appeals Officers, Revenue Agents, Revenue Officers and other IRS personnel. • Coordinated and supervised promoter investigations.• Provided internal training to Office of Chief Counsel Attorneys and IRS personnel.• Case issues included partnership, international, transfer pricing, offshore employee leasing, 419, 183, ADA tax credit, corporation sole, estate and gift, ERISA, CDP, research credit, bankruptcy, administrative and litigation fees, collection, penalty and interest abatement disclosure and fraud. Show less