I have more than 20 years of experience representing private taxpayers before the IRS. During that time I have handled all types of Tax Controversies and Tax Problems on behalf individuals and businesses. My experience includes representing taxpayers at all levels of the IRS in tax collection, audit, filing and reporting matters. My Tax Resolution practice frequently involves representing taxpayers who have very significant tax liabilities and taxpayers that have failed to file their income tax returns for many years and want to get back on track with the IRS and settle their tax liabilities through affordable Offers in Compromise or want to make arrangements to resolve their tax problems over time on an affordable basis, with some taxpayers needing up to 12 months to get their financial affairs in order before making more meaningful monthly payments on Installment Agreements. My tax audit experience includes tax return audits with both civil fraud and criminal tax exposure and significant tax and penalty liability exposure. Tax advisory experience includes all areas of income tax, sales tax and gift and estate tax law and service to individuals, corporations, partnerships, limited liability companies, trusts, estates and to other tax professionals and non-tax professionals. When I work with other tax professionals such as Registered Tax Preparers, Bookkeepers, Accountants and Enrolled Agents, I encourage working as a team to best serve our mutual clients. If another tax professional requests my assistance, I encourage the continued relationship between that tax professional and his or her client and I am happy to work on a limited scope basis by allowing the other tax professional to continue all work I am not needed to perform in representing our mutual clients. I am authorized to practice before the IRS in all jurisdictions and authorized to practice before the US Tax Court.
TAX ATTORNEY, OFFICE OF THE CHIEF COUNSEL
NATIONAL OFFICE WASHINGTON, DC
Repeat IRS Chief Counsel Special Act Award Recipient
Taxation of partnerships, limited liability companies, corporations, trusts, estates & individuals.
Tax legislation: participated in the development and drafting of tax legislation and handled congressional tax inquiries on behalf of the IRS. Worked with IRS Chief Counsel, District Counsel, District Director on complex matters of tax regulation, compliance, enforcement, audit and litigation. Authored and published: tax regulations; IRS Revenue Rulings, IRS Revenue Procedures, IRS Private Letter Rulings, and internal IRS /Treasury Memoranda involving complex issues of Federal Taxation. Published: Journal of Partnership Taxation (Wg&L) Partnerships with Tax-Exempt Partners Given Guidance On Avoiding UBTI. Speaker American Bar Association Partnership Tax Section.
Graduated with Honors University Of Connecticut School Of Law. Graduated University Of Rhode Island, B.S. Engineering High Honors (Number 2 Rank In Class)(Tau Beta Pi Engineering Honor Society), Judicial Law Clerk To Senior Associate Justice Of The Supreme Court Of Rhode Island, New York University School Of Law/Internal Revenue Service: Education Program, 17 Semester Tax Law Courses