Represented a partnership in litigation regarding the validity of IRS regulations under the Administrative Procedures Act (APA). The Tax Court held that Treas. Reg. § 1.170A-14(g)(6)(ii) was procedurally invalid under the APA, reversing its prior holding in Oakbrook Land Holdings, LLC v. Commissioner, 154 T.C. 180 (2020). See Valley Park Ranch, LLC v. Commissioner, 162 T.C. No. 6 (Mar. 28, 2024).
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 partnership in Tax Court litigation involving Section 6751(b) penalty approval procedures. The Tax Court imposed sanctions on the IRS for its conduct in backdating approval documents and attempting to cover up such conduct, which our team identified through strategic use of the Tax Court’s discovery process. See LakePoint Land II, LLC v. Commissioner, T.C. Memo. 2023-111.
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 from the IRS.
Represented one of the nation’s largest healthcare systems in securing a full concession of an IRS proposed $200 million transfer pricing adjustment between its related tax exempt and non-tax-exempt entities.
Represented the primary owner of the parking meter system for one of the nation’s largest cities in securing a full concession of an IRS proposed $50 million depreciation adjustment.
Represented a national provider of physical therapy and orthopedic rehabilitation services in securing a multimillion-dollar concession of proposed basis-shifting adjustments between related-party partnerships.
Represented several of the nation’s largest financial institutions in securing concessions in tens of millions of dollars of proposed adjustments to research and development tax credits for the development of software from the IRS.
Represented one of the nation’s largest theatre circuits in securing hundreds of thousands of dollars of proposed employment tax adjustments (worker classification, defined benefit plans, fringe benefits, executive compensation, non-qualified deferred compensation, etc.) from the IRS.
