Portland, OR
Tax Lawyer at Portland, OR
Practice Areas: Tax
OUTCOME: See http://www.ca9.uscourts.gov/datastore/opinions/2012/12/19/11-70819.pdf
Interpretation of technical language in alternative minimum tax net operating loss carryover relief rule
OUTCOME: See http://www.ustaxcourt.gov/InOpHistoric/Hutch2.TC.WPD.pdf
Represented developer of residential golf community in IRS challenge to tax treatment of development costs.
OUTCOME: Summary judgment for United States
Represented 3,500 ex-IBM employees in consolidated refund actions; tax issues related to income and FICA tax treatment of payments made to departing employees to avoid potential lawsuits.
OUTCOME: Summary judgment for United States
Companion case to Abbott in Court of Federal Claims.
OUTCOME: Summary judgment for United States
Tax refund action related to application of tax benefit rule to former corporate add-on minimum tax.
OUTCOME: Cert. denied
Represented the Government of the Virgin Islands in opposing cert petition; tax issue related to application of the “mirror system” of taxation in the U.S. Virgin Islands.
OUTCOME: Cert. denied
Represented the Government of the Virgin Islands in opposing cert petition; tax issue related to application of a targeted transitional rule in the Tax Reform Act of 1986.
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