Represented an entertainment company in securing a full government concession for a $170 million worthless stock deduction in IRS Appeals.
Represented an individual in securing in excess of a $20 million concession of a proposed adjustment related to the at-risk rules to multiple partnerships in IRS Appeals.
Represented a national retailer in securing in excess of a $100 million concession of a proposed adjustment related to implementation of the Tangible Property Regulations in IRS Appeals.
Valley Park Ranch, LLC v. Comm’r, 162 T.C. No. 6 (Mar. 28, 2024)
Holding Treas. Reg. § 1.170A-14(g)(6)(ii) procedurally invalid under the APA; reversing Oakbrook Land Holdings, LLC v. Comm’r, 154 T.C. 180 (2020).
LakePoint Land II, LLC v. Comm’r, T.C. Memo. 2023-111
Section 6751(b) penalty approval; sanctions imposed on IRS.
Whitehouse Hotel Ltd. P’ship v. Comm’r, 139 T.C. 304 (2012)
Façade easement; valuation issues.
Butler v. Comm’r, C. Memo. 2012-72
Conservation easement; valuation issues.
Buyuk LLC, et al. v. Comm’r, T.C. Memo. 2013-253
Distressed asset/debt transaction.
Dunn v. Comm’r, T.C. Memo. 2010-198
Aircraft passive activity loss.
Schrimsher v. Comm’r, T.C. Memo. 2011-71
Façade easement; contemporaneous written acknowledgment.
Kennedy v. Comm’r, T.C. Memo. 2009-57
Passive losses; net operating loss carryforwards.