Jon Feldhammer Email & Phone Number

San Francisco

Practice focuses in tax controversy, tax compliance, and taxation.

San Francisco, Ca

Practice focuses in tax controversy, tax compliance, and taxation.

201 Mission Street, Ste 2270, San Francisco, Ca 94105

Practice focuses in tax controversy, tax compliance, and taxation.

San Francisco, California

• Lead attorney in the landmark treaty case Santos v. Commissioner, 135 T.C. 447 (2010) and 13 other trials in front of the United States Tax Court.• Litigation experience includes drafting pleadings, briefs and motions, arguing motions, preparing and responding to discovery requests, conducting settlement negotiations, taking and defending depositions, hiring and preparing expert witnesses, and engaging in all aspects of trial preparation up to and including trial.• Advise revenue agents during complex audits and litigate issues involving: o gift and estate taxes including valuation of fractional ownership interests; real estate; and blockage discounts; o international taxes including treaty issues; foreign bank accounts (FBAR penalties); controlled foreign corporations; fixed, determinable, annual, or periodic (FDAP) income; foreign earned income exclusion, and the offshore voluntary disclosure initiative;o corporate and partnership taxes including hedge funds; and TEFRA entities and procedure; o civil and criminal tax fraud; o tax shelters including custom adjustable rate debt structure (CARDS); and a research and development shelter; ando individual income taxes including passive activity losses; unreported income; conservation easements; and hobby losses.• Teach classes to revenue agents and appeals officers about interviewing skills, tips for civil fraud audits, tax procedure, Federal Rules of Evidence, and specific areas of the tax law.• Write memoranda advising Department of Justice Attorneys and Assistant United States Attorneys in collection actions, summons enforcement, and refund lawsuits.