Michael Cowan, J.D., LL.M.

General Attorney (Tax) at IRS, Office of Chief Counsel
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Contact Information
us****@****om
(386) 825-5501
Location
Detroit Metropolitan Area

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Credentials

  • Attorney
    State Bar of Michigan
    May, 2012
    - Oct, 2024

Experience

    • United States
    • Law Practice
    • 400 - 500 Employee
    • General Attorney (Tax)
      • May 2022 - Present

    • United States
    • Law Practice
    • 1 - 100 Employee
    • Senior Tax Attorney
      • 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

    • United States
    • Law Practice
    • 1 - 100 Employee
    • Tax Attorney
      • 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

    • United States
    • Human Resources Services
    • 500 - 600 Employee
    • Managed Document Reviewer
      • 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

    • United States
    • Legal Services
    • 1 - 100 Employee
    • Attorney
      • 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

    • Attorney
      • 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

    • United States
    • Financial Services
    • 1 - 100 Employee
    • Compliance Specialist
      • 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

    • Extern (Office of Chief Counsel, Internal Revenue Service)
      • 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.

Education

  • Thomas M. Cooley Law School
    LL.M, Taxation
    2012 - 2013
  • Thomas M. Cooley Law School
    Doctor of Law (J.D.), Taxation
    2008 - 2012
  • University of Michigan-Flint
    Bachelor of Arts (B.A.), History/Political Science
    2004 - 2008
  • Grand Blanc High School
    High School Diploma, General Education
    2000 - 2004

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