El Prado, NM
Tax Lawyer at El Prado, NM
Practice Areas: Tax
OUTCOME: Decided for the Government
This was a "constructive receipt" case involving one of over 100 former consulting partners of E&Y that I represented in connection with their individual tax liabilities deriving from their affiliation ... in 2000 with the French consulting firm of Cap Gemini, S.A.
OUTCOME: Decided for the Government
Collection Due Process matter
OUTCOME: Consulting
From 1997-2003, in addition to my regular practice and due in significant part to my involvement with the ITC litigation while with the Government, I was retained by KPMG LLC as an independent consulta ... nt. At KPMG I prepared and conducted seminars for KPMG employees and managers involving the analysis of various areas of the tax law, including certain accelerated depreciation matters, IRS civil and criminal penalties, controversy and litigation considerations, and IRS compliance matters, and also including the principles, concepts, methods, and sources of legal research and analysis at the state and federal levels. The primary purpose of my retention was to compile and synthesize all relevant authority regarding certain depreciation issues, to advise KPMG on the proper development and preservation of the relevant supporting evidence to document compliance with those authorities, and further, to advise KPMG not only on the status of certain other areas of the tax law, but also on the practices and procedures, including audit practices and procedures and litigating positions, of the IRS and DOJ. Specifically for this purpose, I was sent to DC to meet with various officials of the IRS and DOJ to remain updated on the current thinking of, and thereafter to maintain contact with, the Government personnel in charge of these matters.
OUTCOME: Counsel 2004-2013
From 2004-2013, in addition to other aspects of my regular practice, I was retained to represent in excess of 100 former consulting partners of Ernst & Young, LLC, in connection with their individual t ... ax liabilities deriving from their affiliation in 2000 with the French consulting firm of Cap Gemini, S.A. This representation involved all levels of the IRS (audit, collection, and appeals) and litigation (which could not be consolidated) in a number of Federal District and Circuit Courts, the U.S. Court of Federal Claims and the U.S. Court of Appeals For The Federal Circuit, and the U.S. Tax Court.
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