Washington, DC
Litigation Lawyer at Washington, DC
Practice Areas: Litigation
OUTCOME: Judgment in favor of IRS
Plaintiff claimed that his discrimination settlement with his former employer was not FICA or Medicare taxable. Both sides moved for summary judgment.
OUTCOME: Decision in favor of United States
Mary Morris objected to lien which IRS had placed on her property as nominee for her husband. Morris argued the lien was unconstitutional and moved for judgment on the pleadings.
OUTCOME: Judgment for the United States
Three consolidated cases in which Plaintiffs challenged the imposition of penalties with regards to the COBRA Son of BOSS tax shelter. Originally, the Plaintiffs challenged all the adjustments in the ... IRS's Notice of Final Administrative Adjustments but, in the end, Plaintiffs conceded that their COBRA transactions lacked economic substance and challenged only the penalties. After a three week trial, the Court held that the partnerships in this TEFRA action lacked reasonable cause and good faith and, therefore, the 40% penalties were valid at the partnership level.
OUTCOME: Judgment in favor of the United States
Plaintiffs claimed that they had discharge of Indebtedness income prior to 1996. The Court held that plaintiffs showed no proof that their creditors had discharged their debts.
OUTCOME: Decision in favor of the United States
The United States requested that the Judicial Panel on Multi-District Litigation transfer two cases from the Western District of Texas to the Southern District of Indiana so that all the cases dealing ... with the infamous COBRA Son of BOSS tax shelter could be centralized for purposes of discovery. Taxpayers opposed the request. The Panel found in favor of the United States.
OUTCOME: Judgment in favor of United States
Plaintiff claimed that the IRS improperly seized her property. The Court dismissed Plaintiff's claim under the Declaratory Judgment Act and the Anti-Injunction Act.
OUTCOME: Remand Denied
Plaintiff stakeholder requested reasonable fees or, if the Court could not grant such fees, that the matter be remanded to the State Court, from which Mr. Steiner had removed the action to the Federal ... District Court. The Court agreed with Mr. Steiner that Plaintiff's request for remand was untimely, and that Plaintiff could not recover fees to the extent that such recovery would lower the amount of a prior federal lien.
OUTCOME: Determination in favor of the Commissioner
Petitioner-husband transferred his interest in real property to Petitioner-wife as part of a separation agreement. Petitioners claimed that this was a non-taxable transfer. Tribunal held that the tra ... nsfer was made in exchange for the transferee's relinquishment of marital rights and was therefore taxable.
OUTCOME: Outcome in favor of Commissioner.
Commissioner determined a deficiency for the Petitioner for tax year 1996, finding that Gary Halpern was an officer whose salary should have been added back to determine taxable income. Petitioner arg ... ued that Gary Halpern was not an officer in 1996. After Hearing, the Tribunal determined that Gary Halpern was indeed an officer in 1996.
OUTCOME: Determination in favor of Commissioner
Petitioner filed untimely requests for refund of Commercial Rent Tax. Tribunal found that it did not have jurisdiction to grant untimely requests.
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