Associate Attorney
CurrentDefending client in district court over collection action for willful FBAR penalty. Drafted answer to complaint, discovery requests and responses, and motion for summary judgement. Sat first chair taking deposition of IRS employee. Coordinated preparation of expert report with client’s accountant.Advising client on whether his CFC was engaged in a U.S. trade or business earning effectively connected income. Analyzing company records and regularly communicating with company employees to formulate recommendation on how to report CFC's income for prior years.Drafted protest letters disputing proposed adjustments and penalties relating to foreign gift reporting and alleged syndicated conservation easement donation deductions.Representing pro bono client to request audit reconsideration of assessment of tax on income from 401(k) distribution.