IRS agreed that taxpayers who raised cattle and ducks for their duck hunting preserve were engaged in farming activities for profit. 

Represented taxpayer in criminal worker classification case in the Northern District of Georgia. The jury acquitted the taxpayer of all tax charges.

Recently tried conservation easement case involving a charitable contribution deduction on the donation of 500 acres along five miles of navigable water near the Atlantic Ocean. Decision pending in the United States Tax Court.

Obtained innocent spouse relief from all tax liabilities for innocent spouse.

Recently tried conservation easement case involving the disallowance of a charitable contribution deduction on the donation of a golf course to a conservation easement. Decision pending in the United States Tax Court.

Represented a bank lender in the financing of a tax credit syndicate using ownership interests in the entities owning film tax credits as collateral for the loan. 

IRS agreed owner of Lear Jet entitled to interest, deprecation and operating expense deductions.

Represented one of the world's largest religious organization before the Georgia Department of Revenue, which agreed not to impose sales use and lodging taxes on use of lodging facility by church members and related groups.

Representing business entities in a wide variety of industries on top matters related to formation, financing, operations, restructuring, and dispositions.

Represented business owners, plan sponsors, trustees, lenders, and related clients in a wide variety of tax issues arising in Employee Stock Ownership Plan ("ESOP") transactions ranging in value from $10-$300 million.

Advised numerous S Corporations, LLCs and partnerships, and their owners, regarding initial qualification and the taxation of operating and investment income, raising debt and equity capital, executive compensation, and disposition of assets or entities.

Representing large, complex group of foreign entities, including a private foundation and its founders in an IRS examination involving classification and taxation of entities with more than $50 million of tax and penalties at stake.

Represented retired NFL football player in case where the IRS denied a theft loss the taxpayer suffered when his licensed investment adviser misappropriated $1,679,500 of his funds. Decision pending in the United States Tax Court.

The IRS denied fuel excise tax credits for industrial vacuum loaders known as “Guzzlers” used by an industrial waste removal company. The government recognized the hazards of litigating the case and agreed for purposes of this case that the equipment qualified as Off-Highway Vehicles engaged in an off-highway business use and, therefore, qualified for the fuel excise tax credit.

The Tax Court agreed that gifts of family limited partnership interests in a family limited partnership for an incompetent taxpayer under guardianship did not violate §2036.

IRS conceded challenge to Amendment Clause in Conservation Easement and settled on eve of trial reducing the alleged deficiency by more than $1.2 million.

The IRS asserted that the taxpayer did not materially participate in his yacht charter business and therefore the business was passive and his losses were not deductible.

Through a chronology of Petitioner’s business records, charter agreements, phone records, emails, and co-worker’s testimonials, the taxpayer established that he not only materially participated in the business operations of his yacht charter business, but also micro-managed that ...

Successfully represented many clients seeking reduced penalties under the IRS offshore voluntary disclosure.

The IRS abated penalties against NFL Football players who unwittingly invested in tax scam and provided information that resulted in criminal indictment of promoter.

Represented solar, wind, and biomass renewable energy developers in the structuring of entities to raise equity and debt supported by tax credits and grants.

Representing large non-profit university with respect to domestic and international tax planning, compliance and controversy matters.

Represented group of investment entities on the tax-deferred sale of large tracts of real estate valued at more than $500 million. Structured all kinds of tax-free like-kind exchanges of real estate, including forward, reverse, construction and related-party exchanges.

Represented clients in investigations or in obtaining an opinion or ruling from state or local taxing authorities regarding the application of sales and use tax to various products and services.