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Tax Litigation Representations
Monte Silver v. Internal Revenue Service , No. 19-cv-247 (D.O.C., Dec. 24 2019) (Taxpayer challenge to regulations based upon the Administrative Procedure Act not barred by Anti-lnjunction Act).
Klpfenstein v. Commissioner, T.C. Memo. 2019-1-56 (December 9, 2019) (taxpayer denied claim for award of attorneys' fees).
Broadwood Investment Fund LLC, V. United of States of America , No. 13-55525 (gth Cir. Aug. 3,
2015) (reversing judgment for United States in alleged tax shelter transaction).
AWG Leasing Trust v. United States, 592 F.Supp. 2d 953 (N.D. Ohio 2008) (first trial involving SILO transaction; case involved large documentary record, novel legal issues, and ten testifying experts)
Jade Trading LLC v. United States, 80 Fed. Cl. 11 (2007) (first trial involving Son of BOSS transaction; three week trial presented unique procedural challenges and required extensive coordination with other stakeholders)
Coltec Industries, Inc. v. United States, 454 F.3d 1340 (Fed Cir. 2006), rev’g 62 Fed. Cl. 716 (2004) (first decided case involving contingent liability transaction; three week trial involving thirteen testifying experts and early implementation of electronic document management technology)
Lockheed Martin Corp. v. United States, 210 F.3d 1366 (Fed. Cir. 2000) (applying variance doctrine to bar claims of qualified research expenses)
Rite Aid Corp. v. United States, 255 F.3d 1357 (Fed. Cir. 2001) (invalidating IRS consolidated return regulations)