Michael Cowan, J.D., LL.M.
General Attorney (Tax) at IRS, Office of Chief Counsel- Claim this Profile
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Bio
Credentials
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Attorney
State Bar of MichiganMay, 2012- Oct, 2024
Experience
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IRS, Office of Chief Counsel
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United States
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Law Practice
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400 - 500 Employee
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General Attorney (Tax)
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May 2022 - Present
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Ayar Law | Tax problems - resolved
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United States
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Law Practice
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1 - 100 Employee
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Senior Tax Attorney
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Sep 2018 - May 2022
• Conduct preliminary investigations to determine the full scope of a client’s tax issue(s) • Assist clients in establishing payment arrangements with the Internal Revenue Service, or State of Michigan, which may or may not involve a more in-depth review of the client’s current financial condition • Perform an in-depth review of taxpayer’s financial condition in order to submit Offers in Compromise to the Internal Revenue Service or the State of Michigan • Assist clients in petitioning for penalty abatements of one or multiple years in which penalties have been assessed • Assist clients with lien removal, discharge, or subordination, depending on their circumstances and likelihood of removal • Negotiate with Revenue Officers of the Internal Revenue Service or State of Michigan, for high net worth clients, to come to terms, and agree on, a resolution • Conduct examinations of high net worth clients that are under audit by the Internal Revenue Service or State of Michigan, and argue to prevent additional tax assessments • Elevate cases to the Internal Revenue Service, or State of Michigan, Appeals Unit or United States Tax Court through an appeal protest letter or Tax Court petition Show less
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Silver Tax Group
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United States
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Law Practice
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1 - 100 Employee
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Tax Attorney
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Mar 2017 - Sep 2018
• Conduct preliminary investigations to determine the full scope of a client’s tax issue(s) • Conduct an initial client financial review to assist with providing the client with the most beneficial resolution for their tax matter based on their financial condition • Assist clients in establishing payment arrangements with the Internal Revenue Service, or state taxing authority, which may or may not involve a more in-depth review of the client’s current financial condition; this includes Offers in Compromise • Assist clients in petitioning for penalty abatements of one or multiple years in which penalties have been assessed • Assist clients with lien removal, discharge, or subordination, depending on their circumstances and likelihood of removal • Negotiate with Revenue Officers of the Internal Revenue Service or state taxing authority, for high net worth clients, to come to terms, and agree on, a resolution • Conduct examinations of high net worth clients that are under audit by the Internal Revenue Service or state taxing authority, and argue to prevent additional tax assessments • Assist clients with criminal tax matters by examining their books and records, for the year(s) in question, and arguing against any intent to defraud the government • Elevate cases to the Internal Revenue Service, or state taxing authority, Appeals Unit or United States Tax Court through an appeal protest letter or Tax Court petition • Manage the legal group to ensure that all matters are being completed in the most thorough and efficient manner possible Show less
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Talent Solutions TAPFIN
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United States
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Human Resources Services
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500 - 600 Employee
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Managed Document Reviewer
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Mar 2016 - Feb 2017
• Assist Ernst & Young, LLP in the litigation process by reviewing documents requested during discovery for relevance and privilege; includes redaction experience • Experience reviewing matters of Pharmaceutical Product Liability and Fraud Investigation • Assist Ernst & Young, LLP in the litigation process by reviewing documents requested during discovery for relevance and privilege; includes redaction experience • Experience reviewing matters of Pharmaceutical Product Liability and Fraud Investigation
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Hire Counsel
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United States
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Legal Services
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1 - 100 Employee
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Attorney
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Mar 2016 - Mar 2016
• Assist in the litigation process by reviewing documents requested during discovery for relevance and privilege • Experience reviewing matters of Business Law and Finance • Assist in the litigation process by reviewing documents requested during discovery for relevance and privilege • Experience reviewing matters of Business Law and Finance
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Advanced Discovery
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Livonia, MI
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Attorney
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Jan 2016 - Feb 2016
• Assist in the litigation process by reviewing documents requested during discovery for relevance and privilege • Experience reviewing matters of International Law, Business Law, Tax Law and Finance • Assist in the litigation process by reviewing documents requested during discovery for relevance and privilege • Experience reviewing matters of International Law, Business Law, Tax Law and Finance
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Hantz Financial
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United States
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Financial Services
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1 - 100 Employee
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Compliance Specialist
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Jul 2014 - Sep 2015
• Review complex financial planning transactions to ensure that they are suitable based on the client’s overall needs and investment strategy • Ensures that the Broker/Dealer maintains, and expands, its Broker/Dealer and Registered Investment Advisor status by complying with various state’s rules and regulations, as well as The Securities and Exchange Commission’s rules and regulations • Draft Letters of Indemnification, for various product companies, in order to hold them harmless for the cancellation and reprocessing of trades • Ensures that all Registered Representatives are properly licensed to sell the various securities and insurance products, that are offered from separate product companies, through the Broker/Dealer and Insurance Agency Show less
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Extern (Office of Chief Counsel, Internal Revenue Service)
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Sep 2011 - Dec 2011
• Wrote various trial preparation documents, including: pre-trial memorandums, stipulations of facts, and Branerton letters. • Researched case law and statutory law for cases that were scheduled for trial; areas of law included: retirement plans, 501(c) non-profit organizations, mileage substantiation (relating to trade workers), and ordinary and necessary business principles. • Wrote various trial preparation documents, including: pre-trial memorandums, stipulations of facts, and Branerton letters. • Researched case law and statutory law for cases that were scheduled for trial; areas of law included: retirement plans, 501(c) non-profit organizations, mileage substantiation (relating to trade workers), and ordinary and necessary business principles.
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Education
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Thomas M. Cooley Law School
LL.M, Taxation -
Thomas M. Cooley Law School
Doctor of Law (J.D.), Taxation -
University of Michigan-Flint
Bachelor of Arts (B.A.), History/Political Science -
Grand Blanc High School
High School Diploma, General Education