Special Trial Attorney

• Jun 2022 - Present

Senior Counsel

• Nov 2018 - Present

I handle complex civil tax disputes in US Tax Court on behalf of the Commissioner of Internal Revenue. The cases in my inventory typically exceed $1 million. I have developed specialties in syndicated conservation easements, abusive charitable remainder annuity trusts, individual international tax compliance, offshore collection issues, abusive return positions and promoter transactions, and procedural expertise in a variety of areas including penalties and penalties defense, administrative procedures, and summons rules and enforcement. My active syndicated conservation easement cases exceed $250 million in adjustments. I have extensive background advising on passthrough entities (including partnerships and S corporations) and the procedural rules for auditing these entities.

Associate Area Counsel

• Nov 2013 - Jan 2018

I managed a group of attorneys and paralegals, overseeing millions of dollars in litigation before the US Tax Court. I advised program managers and group managers in IRS Exam and Collection to craft local field strategies to ensure tax compliance with US tax laws.

General Attorney

• Aug 2004 - Nov 2013