CASE HISTORY: The following descriptions reflect the experience of 20 years in private practice offering legal services specializing in tax controversies and planning to avoid them. It is a brief overview. Many of these matters were national in scope, involving complex and important issues touching upon the administration of the tax laws.
- Brought a variety of tax controversies into the judicial system on behalf of clients; structured dozens of settlement agreements with federal and state civil and criminal authorities, including the United States Attorney for the District of Massachusetts, The Attorney General, Commonwealth of Massachusetts, and the National Offices of the Department of Justice and the Internal Revenue Service.
- Tried dozens of tax controversies from summons enforcement and interpleader to refund and tax deficiency cases both locally and nationally; perfected appeals from dozens of corporate, personal, and professional audits; represented both regional accounting firms and their clients on referral to resolve every manner of tax controversy from collection appeals to criminal tax investigations through to civil settlement, trial, or plea. Inquiries are welcome into any matters to be qualified to particular issue experience. Some particular case examples follow.
- Represented: an oil company owner/shareholder in income tax case arising from sale of regional oil business owning over 150 gasoline stations; a regional record store expanding its business nationally where expansion was contingent upon resolving past tax collection issues; a marketing corporation in a merger; a nationally recognized author of spiritual guidance books and tapes in obtaining an IRS exemption.
- Represented a nationally published financial advisor in Florida in a case brought by IRS to convert his tax-exempt financial empire to a for-profit corporation and assess him personally for diverted corporate funds as dividends.
- Represented an executive investor in national tax shelter litigation in which the investor was one of four lead petitioners - served as counsel in this case, tried to conclusion in the United States Tax Court with co-petitioners represented by a nationally recognized trial law firm.
- Represented estate of deceased heiress to large fortune, negotiating a pre-trial settlement approved by client which saved over twenty million dollars in taxes.
- Represented Boston businesses, business executives, lawyers, politicians, stock brokers, and establishments, including restaurants, a hospital, automobile dealerships, financial organizations and the like in several matters involving shareholder loans, constructive dividends, responsible officer penalties and other tax-sensitive matters.
- Represented a diverse range of individual business owners in a number of criminal tax invesigations resulting in lenient sentencing after plea agreements and sentencing argument.
