Jacksonville, FL
Tax Lawyer at Jacksonville, FL
Practice Areas: Tax, Wills & Living Wills ... +3 more
OUTCOME: Win for government
122 T.C. 73 (2004): Prohibition on entitlement to fees and costs under I.R.C. § 7430 when taxpayer settles case in Appeals Division prior to the issuance of a Notice of Deficiency or Final Determina ... tion
OUTCOME: Win for government
114 T.C. 276 (2000): First published Tax Court opinion on newly enacted innocent spouse provisions (I.R.C. § 6015).
OUTCOME: Win for government
T.C. Memo. 2000-44: First published Tax Court opinion reviewing whether Commissioner had abused his discretion in refusing to abate interest under I.R.C. sec. 6404(e).
OUTCOME: Win for government
T.C. Memo. 2000-45: Opinion upheld Commissioner’s regulations defining a "ministerial act” under abatement of interest provisions (I.R.C. § 6404).
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