Significant Representations/Relevant Experiences
Planned and drafted domestic and offshore trusts funded by over $100 million in assets.
Authored a successful motion for summary judgment forcing the IRS to voluntarily withdraw a gift tax deficiency assessment. The case involved $3.8 million in alleged estate and gift tax deficiencies.
Obtained a favorable settlement in a case where the United States Department of Justice sought to enjoin the promotion and operation of complex tax transactions that included numerous entities located around the globe and sales of over $1.25 billion in securities.
Successfully opposed a motion for summary judgment in a case involving over $32 million in disallowed tax deductions that allegedly derived from international tax shelter transactions.
Negotiated favorable outcomes with the Internal Revenue Service for clients with previously undisclosed foreign assets.
Represented a client in an immigration case originating from a criminal income tax matter that went before the Supreme Court of the United States.
Served as a law clerk in the Probate Court. Advised Judges on probate administration, trust litigation, conservatorship, and guardianship matters.