- Obtaining favorable outcomes for partnerships and large corporations in matters regarding income tax, employment tax, summons enforcement and civil and criminal penalties.
- Representing high-net-worth individuals with unreported offshore assets. Clients have avoided tens of millions of dollars in penalties.
- Advising a philanthropic organization, with its goal to support start-ups that provide micro-financing to under-served populations, by streamlining its tax reporting and working to reduce its compliance burden.
- Representing individuals and businesses in litigation matters. For example:
- Matter of Sznajderman, Division of Tax Appeals (March 6, 2014)
- National Education Association of the United States v. Comm’r, 137 T.C. 100 (2011)
- Schortmann v. United States, 407 Fed. Appx. 480 (Fed. Cir. 2011)
- Advising multinational businesses with respect to transfer pricing audits and planning.
- Working with the IRS Office of Professional Responsibility to resolve disciplinary inquiries for tax professionals.
- Working with professional services firms and non-profit organizations to evaluate internal tax and bank secrecy compliance procedures and proactively address areas of concern.
- Guiding several energy companies through the IRS audit process and resolving state tax matters.
- Assisting a large management company with respect to New York sales tax.
Professional Organizations and Court Admissions
- District of Columbia Bar
- New York State Bar
- U.S. Tax Court
- U.S. Court of Federal Claims
- U.S. Court of Appeals for the Federal Circuit
- American Bar Association Tax Section
- Federal Bar Association
- Georgetown University Law Center, LL.M. in Taxation with distinction
- Syracuse University College of Law, J.D.
- University of Virginia, B.A.
- Caplin & Drysdale, Chartered
- Latham & Watkins, LLP
- Morgan, Lewis & Bockius, LLP
- Internal Revenue Service, Office of Chief Counsel (extern)
- U.S. Department of Justice, Criminal Division (extern)
Selected Speaking Engagements
- Partnership Recent Developments, Federal Bar Association, Tax Law Conference (March 3, 2017)
- Sensitive Business Audits, Online Compliance Panel (November 22, 2016)
- Worker Classification and the Tax Court, American Bar Association, Section of Taxation, 2016 Joint Fall CLE Meeting, September 30, 2016
- Nuts and Bolts of an IRS Audit, Massachusetts Society of Enrolled Agents (September 22, 2016)
- Federal Tax Updates, Dallas CPA Society (August 10, 2016)
- Understanding Stages and Strategies in a Criminal Tax Case, Bloomberg BNA Webinar (July 27, 2016)
- Ethical Considerations in Drafting Tax Opinions, American Bar Association, Forum on Affordable Housing, May 27, 2016
- Evolution of a Criminal Tax Case, Federal Bar Association, April 1, 2016
- TEFRA Partnership Audit Procedures Primer, NYU 74th Institute on Federal Taxation, October 28, 2015
- “The IRS is Coming: How to Prepare for the New IRS Partnership Audit Rules,” National Society of Accountants, Main Street Practitioner Magazine, November 15, 2016.
- "Congress Enacts Entirely New Tax Examination and Collection Regime for Partnerships", with Charles M. Ruchelman, Christopher S. Rizek, Mark D. Allison, and Rachel L. Partain, Caplin & Drysdale Client Alert, December 10, 2015.
- "New Law Changes FBAR Filing Deadline", with Zhanna A. Ziering, Charles M. Ruchelman, Mark D. Allison, Niles A. Elber, Mark E. Matthews, Scott D. Michel, and Matthew C. Hicks, Caplin & Drysdale Client Alert, August 10, 2015
- "Quietly Finding a Home in the Voluntary Disclosure World", with Travis A. Greaves, Tax Notes, Volume 148, Number 2, July 13, 2015
- "US Allows Swiss Banks With Undisclosed Accounts To Wipe the Slate Clean", co-author, Latham & Watkins Client Alert, November 8, 2013.
- Eric Sitarchuk, Mark Srere & Kelly Moore, Corporate Criminal Defense: Compliance, Investigation and Trial Strategies (2010), co-author, Chapter 14, “Unique Procedures and Considerations in Tax Cases.”