United States Tax Court Cases

• Petitioners v. Commissioner: Defending Petitioners against an alleged deficiency relating to the proposed disallowance of certain tax credits. (Case filed in 2023 – Trial not yet scheduled)
• Petitioners v. Commissioner: Defending Petitioners on proposed adjustments relating to the rollover of an IRS. (Case filed in 2022 – Trial not yet scheduled)
• Petitioner v. Commissioner: Defending a Petitioner offshore against certain proposed adjustments relating to Petitioner’s proper tax home. (Case file in 2022 – Trial not yet scheduled)
• Petitioner v. Commissioner: Defending Petitioner’s proposed levy action in a collection due process proceeding. (Case filed in 2022 – Trial not yet scheduled)
• Petitioners v. Commissioner: Defending Petitioners on proposed adjustments relating to income generated from developing and other related services. (Cased filed in 2022 – Trial not yet scheduled)
• Petitioner v. Commissioner: Defending Petitioner, a fiduciary, on issues relating to proposed gift tax adjustments for multiple tax years. (Case filed in 2022 – Trial not yet scheduled)
• Petitioner v. Commissioner: Defending Petitioner, a fiduciary, on proposed adjustments by Commissioner relating to retirement plan distributions and other proposed income and deduction adjustments. (Case filed in 2022 – Trial not yet scheduled)
• Petitioner v. Commissioner: Defending Petitioner, a fiduciary, on an approximate $1 million proposed adjustment relating to the valuation of a 100% interest in a limited liability company for federal estate tax purposes. (Case filed in 2022 – Trial not yet scheduled)
• Petitioner v. Commissioner: Defending Petitioner, a fiduciary, on the proposed disallowance of whether a liability for tens of millions of dollars is deductible for federal estate tax purposes. (Case filed in 2022 – Trial not yet scheduled)
• Petitioner v. Commissioner: Defending Petitioner on proposed adjustments relating to the deductibility of various medical expenses and premium costs. (Case filed in 2022 – Trial not yet scheduled)
• Petitioners v. Commissioner: Defending Petitioners with respect to various income and deductions proposed by Commissioner (Case filed in 2022 – Trial not yet scheduled)
• Petitioner v. Commissioner: Defending Petitioner with respect to the proper fair market value of property to be included on a federal gift tax return. (Case filed in 2021 – Trial not yet scheduled)
• Petitioner v. Commissioner:  Defending Petitioner’s proposed levy action in a collection due process proceeding. (Case filed in 2021 – Trial not yet scheduled)
• Petitioner v. Commissioner:  Defending Petitioner’s proposed levy action in a collection due process proceeding. (Case filed in 2021 – Trial not yet scheduled)
• Petitioner v. Commissioner:  Defending Petitioner against an alleged deficiency of approximately $1.76 million reflected in a substitute for return (“SFR”) filed by the Service. (Case filed in 2021 – Trial not yet scheduled)
• Petitioner v. Commissioner: Defending Petitioner against various proposed income adjustments relating to an alleged tax deficiency between $300,000-$400,000. (Case filed in 2021 – Trial not yet scheduled)
• Petitioners v. Commissioner: Defending Petitioners against an alleged deficiency on the sale of real estate with proposed tax and penalties of approximately $500,000. (Case filed in 2021 – Trial not yet scheduled)
• Petitioner v. Commissioner: Defended Petitioner against proposed adjustments regarding income and various deductions. (Case filed in 2021- Settled before trial)
• Petitioner v. Commissioner: Defending Co-Petitioner in an alleged claim of unreported income, various non-deductible expenses, and a potential innocent spouse claim. (Case filed in 2020 – Trial not yet scheduled)
• Petitioner v. Commissioner: Defended corporate Petitioner on various payroll tax deficiencies. (Case filed in 2021 – Settled prior trial)
• Petitioners v. Commissioner: Defending husband and wife petitioners against proposed adjustments relating to income and various deductions. (Case filed in 2021-Trial not yet scheduled)
• Petitioner v. Commissioner: Defended Petitioner against proposed adjustments relating to offshore income, deductions, and the foreign earned income exclusion. (Case filed in 2021- Settled prior trial)
• Petitioners v. Commissioner: Defended Petitioners against a proposed levy action in a collection due process proceeding. (Case filed in 2021- Settled prior to trial)
• Petitioners v. Commissioner: Defended Petitioners against proposed adjustments relating to gross income and deductions regarding Forms 1099-Misc. (Case filed in 2021- Settled prior trial)
• Petitioner v. Commissioner: Defending Petitioner against proposed adjustments relating to gross income and deductions. (Case filed in 2021-Trial not yet scheduled)
• Petitioner v. Commissioner: Defended Petitioner against proposed adjustments relating to gross income and various deductions. (Case filed in 2021-Settled prior to trial)
• Petitioners v. Commissioner: Defending Petitioners against proposed adjustments of several million dollars and relating to gross income and various deduction. (Case filed in 2021 -Trial not yet scheduled)
• Petitioner v. Commissioner: Defended Petitioner against proposed lien action in a collection due process proceeding. (Case filed in 2021- Settled prior trial)
• Petitioner vs. Commissioner: Defended Petitioner against proposed gross income and related penalty adjustments. (Case filed in 2020 -Settled prior to trial)
• Petitioner vs. Commissioner: Defended Petitioner against proposed adjustments relating to income and various deductions on federal estate tax form 706-NA. (Case filed in 2019 – Settled prior to trial)
• Petitioner vs. Commissioner: Defended Petitioner regarding a proposed adjustment on Form 1099 for proposed income of approximately $400,000. (Case filed in 2019 – Settled prior to trial)
• Petitioner vs. Commissioner: Defended Petitioner against proposed adjustments for deductions taken as a real estate professional and material participation issues. (Case filed in 2019 – Settled prior to trial)
• Petitioner vs. Commissioner: Defended Petitioner against proposed levy action in a collection due process proceeding. (Case filed in 2019 – Settled prior to trial)
• Petitioner vs. Commissioner. Defended Petitioner against a notice of federal tax lien action in a collection due process proceeding. (Case filed in 2019 – Settled prior to trial)
• Petitioner vs. Commissioner. Defended Petitioner against proposed adjustments relating to gross income, deductions, and related penalties. (Case filed in 2019 – Settled prior to trial)
• Petitioners vs. Commissioner: Defended Petitioners against proposed adjustments relating to gross income, deductions, and related penalties flowing from a partnership, Schedule E, and alleged offshore income and expense items. (Case filed in 2019 – Settled prior to trial)
• Petitioners vs. Commissioner: Defended Petitioners against proposed adjustments to gross income and related penalties. (Case filed in 2019 – Settled prior to trial)
• Petitioners vs. Commissioner: Defended Petitioners against proposed adjustments to gross income and related penalties (Case filed in 2019 – Settled prior to trial)
• Petitioner vs. Commissioner: Defended Petitioner against proposed levy action in a collection due process proceeding. (Case filed in 2019 – Settled prior to trial)
• Petitioner vs. Commissioner: Defended Petitioner in an innocent spouse case pursuant to IRC § 6015. (Case filed in 2019 – Settled prior to trial)
• Petitioner vs. Commissioner: Defended Petitioner on proposed adjustments relating to the method of accounting as well as certain other gross receipts triggered by a Form 1099-K. (Case filed in 2019 – Settled prior to trial)
• Petitioners v. Commissioner: Defended Petitioners against proposed adjustments regarding various depreciation deductions and a § 481 adjustment. (Case filed in 2018-Settled prior to trial)
• Petitioners vs. Commissioner: Defended Petitioner against proposed levy action in a collection due process proceeding. (Case filed in 2018 – Settled prior to trial)
• Petitioner vs. Commissioner: Defended Petitioner against proposed gross income adjustments from Form K-1 distributions. (Case filed in 2018 – Settled prior to trial)
• Petitioner v. Commissioner: Defended Petitioner in an innocent spouse matter pursuant to § 6015(f). (Case filed in 2018 – Settled prior to trial)
• Petitioners vs. Commissioner: Defended Petitioners against proposed adjustment to gross income, deductions, and related penalties. (Case filed in 2018 – Settled prior to trial)
• Petitioners vs. Commissioner: Defended Petitioners, on proposed adjustments relating to distributions from a partnership of gross income, deductions, and related penalties. (Case filed in 2018 – Settled prior to trial)
• Petitioners vs. Commissioner: Defended Petitioners on the termination of a partnership interest and whether additional amounts, pursuant to Forms K-1, were discharge of indebtedness under Code Section 108 and related penalties. (Case filed in 2018 – Settled prior to trial)
• Petitioner vs. Commissioner: Defended Petitioner against proposed levy action in a collection due process proceeding. (Case filed in 2018 – Settled prior to trial)
•  Petitioners vs. Commissioner: Defended Petitioners against proposed adjustments relating to gross income and related penalties. (Case filed in 2018 – Settled prior to trial)
•  Petitioners vs. Commissioner: Defended Petitioners against proposed levy action in a collection due process proceeding. (Case filed in 2018 – Settled prior to trial)
• Petitioners vs. Commissioner: Defended Petitioners against proposed adjustments relating to gross income relating to an alleged IRA distribution. (Case filed in 2018 – Settled prior to trial)
• Petitioner vs. Commissioner: Defended Petitioner against proposed adjustment relating to gross income and related penalties. (Case filed in 2018 – Settled prior to trial)
• Petitioner vs. Commissioner: Defended Petitioner on an alleged lack of substantiation for various deductions. (Case filed in 2018 – Settled prior to trial)
• Petitioners vs. Commissioner: Defending Petitioners against proposed adjustments relating to gross Income under § 61 for amounts received from a trust and related penalties. (Case filed in 2017 – Trial not yet scheduled)
• Petitioners vs. Commissioner: Defended Petitioners against proposed adjustments relating to gross income and related penalties. (Case filed in 2017 – Settled prior to trial)
• Petitioner vs. Commissioner: Defended Petitioner against proposed lien action in a collection due process proceeding. (Case filed in 2017 – Settled prior to trial)
• Petitioner vs. Commissioner: Defended Petitioner, as co-counsel, against millions of dollars in potential employment taxes in a proceeding challenging the entire underlying tax liability. (Case filed in 2017 – Decision in favor of Petitioner)
• Petitioner vs. Commissioner: Defended Petitioner, as co-counsel, against millions of dollars in potential employment taxes in a proceeding challenging the entire underlying tax liability. (Case filed in 2017 – Decision in favor of Petitioner)
• Petitioner vs. Commissioner: Defended Petitioner, as successor lead counsel, against proposed disallowance of various deductions recognized by Petitioner. (Case filed in 2017 – Settled prior to trial)
• Petitioner vs. Commissioner: Defended Petitioner against proposed adjustments relating to gross income, net operating loss deductions recognized, and related penalties. (Case filed in 2017 – Settled prior to trial)
• Petitioner vs. Commissioner: Defended Petitioner against a notice of federal tax lien action in a collection due process proceeding. (Case filed in 2017 – Settled prior to trial)
• Petitioner vs. Commissioner: Defended Petitioner against a notice of federal tax lien action in a collection due process proceeding. (Case filed in 2016 – Settled prior to trial)
• Petitioner vs. Commissioner: Defended Petitioner against a notice of federal tax lien action in a collection due process proceeding. (Case filed in 2016 – Settled prior to trial)
• Petitioners vs. Commissioner: Defending Petitioners against proposed adjustments relating to income, deductions recognized, and related penalties for residential-rental real estate. (Case filed In 2016 – Trial not yet scheduled)
• Petitioner vs. Commissioner: Defended Petitioner against proposed adjustments relating to gross income, deductions recognized, and related penalties. (Case filed in 2016 – Settled prior to trial)
• Petitioner vs. Commissioner: Defended Petitioner against proposed adjustments relating to gross income, deductions recognized, and related penalties. (Case filed In 2016 – Settled prior to trial)
• Petitioners vs. Commissioner: Defended Petitioners against proposed adjustments relating to gross Income, deductions recognized, and related penalties for amounts received from a closely-held entity and whether such receipts were an actual or constructive dividend vs. a non-taxable return of capital In excess of several million dollars. (Case filed in 2016 – Settled prior to trial)
• Petitioner vs. Commissioner: Defended Petitioner on a valuation issue greater than $23 million for closely­ held stock for estate tax purposes and other related gross estate and deduction issues. (Case filed in 2015 – Settled prior to trial)
• Petitioner vs. Commissioner: Defended Petitioner in a tax dispute relating to whether various workers were employees vs. independent contractors. (Case filed in 2015- Settled prior to trial)
• Petitioner vs. Commissioner: Defended Petitioner against proposed levy action in a collection due process proceeding. (Case filed in 2014 – Settled prior to trial)
• Petitioners vs. Commissioner: Defended Petitioners against proposed adjustments relating to gross income, income tax credits are taken, and related penalties. (Case filed in 2014 – Settled prior to trial)
• Petitioner vs. Commissioner: Defended Petitioner against proposed adjustments relating to gross income and related penalties. (Case filed in 2014 – Settled prior to trial)
• Petitioner vs. Commissioner: Defended Petitioner on proposed adjustments relating to split-dollar arrangements with respect to the cash surrender value of life insurance where Commissioner sought approximately $11.3 million in additional estate tax and $3.3 million in additional penalties. (Case filed in 2013 – Settled prior to trial)
• Petitioner vs. Commissioner: Defended Petitioner on proposed adjustments relating to an alleged imputed gift of several million dollars. (Case filed in 2013 – Settled prior to trial)
• Petitioners vs. Commissioner: Defended Petitioners against a notice of federal tax lien in a collection due process proceeding. (Case filed in 2012 – Dismissed prior to trial)
• Petitioners vs. Commissioner. Defended Petitioners against proposed adjustments relating to itemized deductions recognized and related penalties. (Case filed in 2012 – Settled prior to trial)
• Petitioner vs. Commissioner: Defended Petitioner relating to an IRS petition for transferee liability pursuant to IRC § 6901, where Commissioner was seeking to collect over $40 million in tax, penalties, and interest under an alleged tax avoidance (Midco) scheme. (Case filed in 2011 – Settled prior to trial)
• Petitioner vs. Commissioner: Defended Petitioner against a notice of federal tax lien action in a collection due process proceeding. (Case filed in 2010 – Settled prior to trial)
• Petitioners vs. Commissioner: Defended Petitioners against proposed lien action in a collection due process proceeding. (Case filed in 2010 – Settled prior to trial)
• Petitioner vs. Commissioner: Defended Petitioner against proposed levy action in a collection due process proceeding. (Case filed in 2010 – Settled prior to trial)
• Petitioners vs. Commissioner. Defended Petitioners against proposed levy action in a collection due process proceeding. (Case filed in 2009 – Settled prior to trial)
• Petitioner Commissioner: Defended Petitioner against proposed levy action in a collection due process proceeding. (Case filed in 2009 – Settled prior to trial)
• Petitioner vs. Commissioner: Defended Petitioner against proposed levy action in a collection due process proceeding. (Case filed in 2009 – Settled prior to trial)
• Petitioner vs. Commissioner: Defended Petitioner against proposed levy action in a collection due process proceeding. (Case filed in 2008 – Settled prior to trial)
• Petitioner vs. Commissioner: Defended Petitioner against proposed levy action in a collection due process proceeding. (Case filed in 2008 – Settled prior to trial)
• Petitioner vs. Commissioner. Defended Petitioner against proposed levy action in a collection due process proceeding. (Case filed in 2008 – Settled prior to trial)
• Petitioners vs. Commissioner: Defended Petitioner on the proposed disallowance of various hobby loss deductions under IRC § 183 and related penalties. (Case filed in 2006 – Settled prior to trial)
• Petitioner vs. Commissioner: Defended an S Corporation on its conversion from a C to an S corporation and an alleged built-in gain and tax of approximately $1.4 million, plus related penalties. (Case filed in 2006 – Settled prior to trial)
• Petitioner vs. Commissioner. Defended Petitioner against proposed adjustments relating to gross income, deductions recognized, and related penalties. (Case filed in 2005 – Settled prior to trial)
• Petitioner vs. Commissioner: Defended Petitioner, in a co-counsel capacity, on the valuation of the fair market value of leasehold interest and other related issues of an estate. (Case filed in 2005 – Settled prior to trial)
• Petitioner vs. Commissioner: Defended Petitioner at tax court trial relating to whether certain personal injury damages were gross income pursuant to Code Section 104. (Case filed in 2005 – Settled post-trial)
• Petitioner vs. Commissioner: Defended Petitioner against proposed adjustments relating to gross income, deductions recognized, and related penalties. (Case filed in 2005 – Settled prior to trial)
• Petitioner vs. Commissioner: Defended Petitioner on proposed adjustments relating to the gross estate, interest, and penalties of approximately $1 million. (Case filed in 2004 – Decided on summary judgment)
• Petitioner vs. Commissioner: Defended Petitioner on various proposed adjustments and related penalties. (Case filed in 2003 – Settled prior to trial)

United States District Court & Courts of Appeals

• Plaintiffs vs. United States of America: Represented Plaintiffs in the United States District Court, Northern District of Illinois relating to a refund claim triggered by the utilization of certain suspended passive losses carried forward into a subsequent year. (Case filed in 2019 – Settled prior to trial for amount sought)
• Plaintiff v. United States of America: Represented Plaintiff In the Western District of New York on a refund suit rotating to a “financial disability” pursuant to Rev. Proc. 99-21. (Case filed in 2016 – Resolved by Court Decision – pretrial)
• Plaintiff v. United States of America: Represented Plaintiff in the United States District Court, Middle District of Florida, Tampa. (Case filed in 2015 – Settled prior to trial)
• Plaintiff vs. United States of America: Represented Plaintiff in the United States Court of Appeals for Federal Circuit relating to an appeal of a denial of an abatement of penalties. (Case filed in 2012 – Court of Appeals affirmed trial court)
• United States of America vs. Defendant: Represented Defendant in the United States District Court, Northern District of Illinois in an action to reduce assessed taxes to a judgment within the 10-year collection statute under the Internal Revenue Code. (Case filed in 2012 – Settled after appeal to the 7th Circuit)
• United States of America vs. Defendant: Represented Defendant in the United States Court of Appeals for the Seventh Circuit on an appeal of a default judgment obtained by the United States in the District Court for tax deficiencies. (Case filed in 2012 – Settled pre-oral argument)
• Plaintiff vs. United States of America: Represented Plaintiff in the United States Court of Federal Claims on a claim for refund. (Case filed in 2011 – Settled prior to trial)
• Plaintiffs vs. United States of America: Represented Plaintiffs in the United States Court of Appeals for the Ninth Circuit in a tax refund suit for millions of dollars relating to whether one or more plaintiffs were liable for employment taxes in a PEO context. (Case filed 2010 – Summary judgment entered for Plaintiffs)
• Plaintiffs vs. United States of America: Represented Plaintiffs in the United States District Court, Southern District of New York relating to gross income issues on the sale of qualified replacement property pursuant to § 1042. (Case filed in 2010 – Settled prior to trial)
• Plaintiffs vs. United States of America: Represented Plaintiffs in the United States District Court, Eastern District of New York relating to gross income issues on the sale of qualified replacement property pursuant to § 1042. (Case filed 2010 – Settled prior to trial)
• United States of America vs. Defendant: Represented Defendant in the Middle District of Florida, Tampa Division. (Case filed in 2010 – Settled prior to trial)
• Plaintiff v. United States of America: Represented Plaintiff in the Northern District of Illinois, Eastern Division. (Case filed in 2010 – Settled prior to trial)
• Plaintiffs vs. United States of America: Represented Plaintiffs in an appeal from the United States District Court in a tax refund suit in the millions of dollars relating to whether one or more plaintiffs were responsible for certain employment taxes in a PEO context. (Case filed in 2008 – Summary judgment entered for government; summarily reversed on appeal by the 9th Circuit)
• United States of America vs. Defendant: Represented Defendant in the United States District Court, Eastern District of Wisconsin in an action brought by the United States of America for millions of dollars of tax deficiencies (and defended against a foreclosure) action related to various federal tax liens. (Case filed in 2005 – Settled prior to trial)
• Plaintiff vs. United States of America: Represented Plaintiff In the United States District Court, Northern District of Illinois, Eastern Division, relating to the classification of workers as independent contractors vs. employees. (Case filed in 1996 – Settled prior to trial)