Experience

IRS, Office of Chief Counsel

• United States
• Law Practice
• 400 - 500 Employee

• Senior Attorney

  • Jun 2022 - Present

  Washington DC LB&I Field Counsel



Internal Revenue Service

• United States
• Government Administration
• 700 & Above Employee

• Tax Law Specialist

  • Jul 2012 - Feb 2023

  Greater Chicago Area Litigation rotation assisting an IRS Special Trial Attorney (STA) in analyzing a transfer pricing case that was docketed at the United States Tax Court. The STA was able to bring the case to a settlement resolution favorable to the government in less than a year notwithstanding that it involved complex intangible property. As a Tax Law Specialist my responsibility is to examine transactions of the world's largest taxpayers, issue information document requests and summonses, conduct… Show more Litigation rotation assisting an IRS Special Trial Attorney (STA) in analyzing a transfer pricing case that was docketed at the United States Tax Court. The STA was able to bring the case to a settlement resolution favorable to the government in less than a year notwithstanding that it involved complex intangible property. As a Tax Law Specialist my responsibility is to examine transactions of the world's largest taxpayers, issue information document requests and summonses, conduct interviews, take testimony, prepare notices of proposed adjustment, prepare rebuttal briefs, attend IRS Appeals (Independent Office of Appeals), provide litigation support, work with APMA officials, IRS Counsel, Special Trial Attorneys, and tax officials of foreign tax agencies around the world in joint audits.

• Team Leader - Advance Pricing and Mutual Agreement

  • Sep 2011 - Jul 2012

  Washington, DC Advance Pricing and Mutual Agreement ("APMA") unit located in Washington, DC includes the advance pricing agreement and competent authority functions. We stood APMA up in January of 2012 when we merged APA and CA. As a Team Leader my responsibilities were to lead a team of multi-disciplinary professionals in developing and then negotiating the U.S. tax position regarding APAs and Mutual Agreements. APMA is one unit within Transfer Pricing Operations ("TPO"). The Transfer… Show more Advance Pricing and Mutual Agreement ("APMA") unit located in Washington, DC includes the advance pricing agreement and competent authority functions. We stood APMA up in January of 2012 when we merged APA and CA. As a Team Leader my responsibilities were to lead a team of multi-disciplinary professionals in developing and then negotiating the U.S. tax position regarding APAs and Mutual Agreements. APMA is one unit within Transfer Pricing Operations ("TPO"). The Transfer Pricing Practice is the other unit within TPO.



EY

• United Kingdom
• IT Services and IT Consulting
• 700 & Above Employee

• Partner - Tax Controversy & Risk Management Services

  • Jan 2005 - Apr 2011

  Chicago, Illinois As the Midwest Practice Leader for "Tax Controversy and Risk Management Services", I was responsible for growing the tax controversy practice revenues and for leading a team of highly skilled and experienced former IRS Senior Executives as we represented clients before the IRS examination, Joint Committee and appeals functions. Together we tripled tax controversy revenues from $3 million to $9 million in the Midwest during my time at EY. I was proud to have served as a member of the… Show more As the Midwest Practice Leader for "Tax Controversy and Risk Management Services", I was responsible for growing the tax controversy practice revenues and for leading a team of highly skilled and experienced former IRS Senior Executives as we represented clients before the IRS examination, Joint Committee and appeals functions. Together we tripled tax controversy revenues from $3 million to $9 million in the Midwest during my time at EY. I was proud to have served as a member of the national tax diversity committee. Show less



Misey, Lundeen & Goller

• FEDERAL TAXATION Practice & Procedure (9th & 10th Editions)

  • Jan 2009 - Dec 2010

  CCH a Wolters Kluwer business I co-authored the 9th & 10th Edition of this textbook on federal tax practice & procedure. A year and a half earlier, I had updated the 8th Edition and co-authored the 9th Edition. The textbook is a solid book for an introductory class on federal tax practice & procedure.



Tax Policy Advisor

• Randall Hultgren For Congress

  • Jan 2010 - Nov 2010

  For two campaigns (2010 & 2012) provided Tax Policy Advice to Congressman Randy Hultgren, (R-IL).



University of Illinois

• Visiting Lecturer

  • Jan 2010 - Jun 2010

  Chicago, Illinois I taught my International Tax Policy class as a seminar to graduate accounting majors. After an interim examination on the US international tax law provisions, both inbound and outbound, I assigned students to the positions in Congress (Senate Committee on Finance & Joint Committee on Taxation), in the Treasury Department (Assistant Secretary of the Treasury for Tax Policy, and a few other key Treasury positions) and in the press. We started with the text of then-President Obama' State of the… Show more I taught my International Tax Policy class as a seminar to graduate accounting majors. After an interim examination on the US international tax law provisions, both inbound and outbound, I assigned students to the positions in Congress (Senate Committee on Finance & Joint Committee on Taxation), in the Treasury Department (Assistant Secretary of the Treasury for Tax Policy, and a few other key Treasury positions) and in the press. We started with the text of then-President Obama' State of the Union Message as it pertained to tax law changes. Then, working within the constraints of that year's Tax Expenditure Budget and a senate expenditure rule, the "senators" and the "treasury representatives" negotiated a tax bill, which satisfied the spending constraints, that the president signed into law. All in one semester! Show less



CliftonLarsonAllen LLP. (Then Clifton Gunderson)

• Partner and Firmwide Director

  • Apr 1999 - Dec 2004

  Assisted Todd Craft and others in designing and growing the firm's Multi-State Tax Consulting practice and, later, the firm's International Tax Consulting practice.



Illinois Department of Revenue

• General Counsel

  • May 1995 - Mar 2000

  Under Governor Jim Edgar. I was responsible for the legal aspects of the department's mission such as the legal aspects of tax legislation, tax regulations, tax litigation and other tax guidance for taxpayers. The Office of Internal Affairs (which functions in a manner similar to TIGTA) also reported to me. I was responsible for creating and maintaining relationships with the Attorney General's Office, legislators and their staff, lobbyists, tax practitioner groups and taxpayers.



Office of Associate Chief Counsel (International)

• Senior Attorney

  • Oct 1990 - May 1995

  As an international tax attorney within the Office of Associate Chief Counsel, I was first assigned to Branch 2 and therefore provided legal guidance on subpart F issues. Thereafter, I was assisgned to Branch 5 and provided guidance on foreign currency issues. I led the move to litigate a section 988 case of first impression, Intergraph v. Commissioner, which we won at the US Tax Court and at the 11th Circuit. I was invited to the Advance Pricing Agreement Branch where I led teams that… Show more As an international tax attorney within the Office of Associate Chief Counsel, I was first assigned to Branch 2 and therefore provided legal guidance on subpart F issues. Thereafter, I was assisgned to Branch 5 and provided guidance on foreign currency issues. I led the move to litigate a section 988 case of first impression, Intergraph v. Commissioner, which we won at the US Tax Court and at the 11th Circuit. I was invited to the Advance Pricing Agreement Branch where I led teams that negotiated Advance Pricing Agreements with multinational taxpayers that engaged in continuous global trading of derivatives. Show less



United States Tax Court

• Attorney - Advisor

  • Mar 1988 - Sep 1990

  As an Attorney-Advisor I researched and wrote drafts of tax opinions for the Judge.



Everett Johnson & Breckinridge (later absorbed by LeBouef Lamb)

• Tax Associate, New York City

  • Sep 1984 - Feb 1987

  As an Associate at this distinctive Wall Street tax boutique I prepared legal memoranda and assisted on projects such as section 936 works, extensive section 367 work, a corporate reorganization and a eurobond offering. Our clients included a family with extensive holdings including a large Puerto Rican rum company, a pharmaceutical company with significant operations in Puerto Rico, and most property and casualty insurance companies in the United States, Canada, the UK and Europe. In 1982 we… Show more As an Associate at this distinctive Wall Street tax boutique I prepared legal memoranda and assisted on projects such as section 936 works, extensive section 367 work, a corporate reorganization and a eurobond offering. Our clients included a family with extensive holdings including a large Puerto Rican rum company, a pharmaceutical company with significant operations in Puerto Rico, and most property and casualty insurance companies in the United States, Canada, the UK and Europe. In 1982 we secured the only exception to section 936 intangibles income ever granted by Congress, and I volunteered on the Hill during the 1986 Act for the Chairman of Ways and Means. Show less



United States Senate on staff of David F. Durenberger, United States Senator

• Assistant Tax Legislative Assistant, Washington DC

  • May 1980 - May 1981

  After a short stint on Senator Charles Percy’s staff I worked for Senator Durenberger's Tax Counsel, George Pritts (later Barbara Washburn) on tax matters, several of which eventually became part of the Economic Recovery Tax Act of 1981. I drafted floor speeches introducing tax legislation the Senator sponsored. In addition, I had floor privileges in the Senate Chambers where I accompanied the senator and advised him on floor amendments as they arose. Organized a Finance… Show more After a short stint on Senator Charles Percy’s staff I worked for Senator Durenberger's Tax Counsel, George Pritts (later Barbara Washburn) on tax matters, several of which eventually became part of the Economic Recovery Tax Act of 1981. I drafted floor speeches introducing tax legislation the Senator sponsored. In addition, I had floor privileges in the Senate Chambers where I accompanied the senator and advised him on floor amendments as they arose. Organized a Finance Committee hearing at which the Treasury Secretary agreed to rewrite tax regulations that were so complex they narrowed the usefulness of a code provision written and intended to be widely applicable to farmers, ranchers and small closely held family businesses. Brought Joint Committee Attorneys into meeting some with the senator to obtain advice on language necessary to fulfill his policy objectives. Show less



United States Senate

• Legislative Offices
• 700 & Above Employee

• Assistant Legislative Aide

  • May 1980 - May 1981

  Washington DC Prepared tax legislation, floor speeches, organized Treasury oversight hearing and other meetings and, under the guidance of U.S. Senator Dave Durenberger's Tax Counsel, worked on all aspects of a major tax act, from start to finish, sought by President Reagan: the Economic Recovery Tax Act of 1981.



Price Waterhouse & Co.

• Staff Accountant

  • Sep 1978 - Mar 1980

  Staff Accountant in both Audit and Tax Departments