Profile

Jeff is a tax controversy and litigation attorney with a strong technical tax background as well as a deep understanding of inner-workings of the Internal Revenue Service. Jeff’s practice focuses on representing clients in IRS examinations, appeals and litigation. His knowledge, combined with strong strategic thinking and negotiation skills allows him to effectively advocate for his clients before the IRS.

Previously, Jeff led the regional Tax Controversy practice for a "Big Four" accounting firm, where he assisted clients in resolving disputes administratively within the IRS either while still in examination or before the IRS Office of Appeals. Jeff’s client base was diverse; he routinely advised Fortune listed companies, private equity firms, closely held businesses and high net worth individuals. Some areas in which Jeff has assisted clients included: repairs regulations disputes; section 197 intangible amortization; foreign tax credit issues; bad debt and worthless stock deductions; accounting method changes; compensation related issues and claims for the research credit and domestic production deductions.

Jeff began his career with the IRS Office of Chief Counsel a litigator; eventually being appointed as a Special Trial Attorney in the Large Business and International Division where he was responsible for advancing some of the most important, sensitive and complex cases before the United States Tax Court. Jeff’s prior experience representing the IRS in tax cases included matters involving: variable prepaid forward contracts; Subpart F income; characterization issues related to aircraft (including passive activity limitations and questions of personal use) and conservation and façade easement transactions (including complex valuation issues).

Significant Cases

• Whitehouse Hotel Ltd. P’ship v. Comm’r, 139 T.C. 304 (2012) (façade easement; valuation issues)
• Butler v. Comm’r, T.C. Memo. 2012-72 (conservation easement; valuation issues)
• Buyuk LLC, et. al. v. Comm’r, T.C. Memo. 2013-253 (distressed asset/debt transaction)
• Dunn v. Comm’r, T.C. Memo. 2010-198 (aircraft passive activity loss)
• Schrimsher v. Comm’r, T.C. Memo. 2011-71 (façade easement; contemporaneous written acknowledgment)
• Kennedy v. Comm’r, T.C. Memo. 2009-57 (passive losses; net operating loss carryforwards)

Professional Affiliations

• American Bar Association, Tax Section

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