Highly experienced, analytical attorney specializing in estate planning, tax, audit, and procedural and business issues at state and federal levels. Certified as a Tax Specialist by the State Bar of California. Leader in professional and community organizations. Vietnam Veteran.
Co-leader of annual Washington trip at which academic papers are presented to the Internal Revenue Service, U.S. Treasury Department, U.S. Tax Court, and the attorneys for the House and Senate tax writing committees and Joint Committee on Taxation.
Expert in tax audits and tax appeals. Years of primary responsibility for numerous tax audits (primarily field audits) - both state (Franchise Tax Board, State Board of Equalization, Employment Development Department) and federal tax appeals, U.S. Tax Court petitions, Offers-in-Compromise and Installment Agreements, Innocent Spouse Applications, and trust fund penalty and other tax collection issues.
Supervision of the preparation of over 7,500+ individual, gift and estate, trust, pension, partnership, and corporate tax returns.
Provider of legal and tax services to over 800 clients ranging from individual taxpayers, partnerships, trusts and estates, pension plans, small corporations and limited liability companies, to multi-national corporations.
As a result of this involvement, I am familiar with issues of choice and structure of entity, tax treatment of capital gains, deductions, methods of accounting, timing of income, installment sales, sales of corporate assets and corporate stock, independent contractor issues, water's edge elections, tax treaties, pension plan investments and loans, leases, financing and lease treatment of tenant improvements, estate planning, and so forth.
Licensed since 1972
|Award Name||Grantor||Date Granted|
|Super Lawyer||Super Lawyers||2011|
|Five Star Wealth Manager||Five Star Professional||2011|
|Super Lawyer||Super Lawyers||2010|
|Super Lawyer||Super Lawyers||2009|
|Instructor of Corporate Taxation||University of San Diego School of Business||2004 - 2005|
|Taxation and Estate Planning Attorney at Law||CPA and Law Offices||1994 - Present|
|Real Estate Broker||Self Employed||1974 - 2002|
|General Contractor (B-1 license)||Self Employed||1974 - 1990|
|Captain - Active Duty||United States Army Reserves||1969 - 1971|
|Association Name||Position Name||Duration|
|State Bar of California, Taxation Section||Chairman||2005 - 2006|
|State Bar of California, Taxation Section, Tax Procedure and Litigation Committee||Editor of quarterly newsletter||2004 - 2005|
|San Diego County Bar Association, Taxation Law Section||N/A||N/A|
|California Tax Lawyer Magazine||Qualified Amended Returns: Expanding the Safe Harbor||2009|
|California Tax Lawyer Magazine||Common Ground...Conservation Easements: Matching Conservation Values to the Public with Tax Benefits to the Donors||2008|
|California Tax Lawyer Magazine||Funding the Internal Revenue Service as an "Off-Budget" Agency||2007|
|Journal of Taxation||Can an Attorney Participate in the Writing of an Expert's Witness Report in Tax Court||2004|
|California Tax Lawyer Magazine||Valuation and Court-Appointed Experts: Hats Off to the U.S. Tax Court for Using Federal Rule of Evidence Â§706||2002|
|California Tax Lawyer Magazine||If the Net Income or Gain Allocated to a Non-Material Partner Securities (Trading) Partnership is 'Not From a Passive Activity,' Then What Is It?||1999|
|University of San Diego School of Law||Taxation||LL.M - Master of Laws||N/A|
|University of Nebraska College of Law||Law||JD - Juris Doctor||N/A|
|Ohio State University||Accounting||BS - Bachelor of Science||N/A|