Experience

Rating: 10.0 (Superb)

Honors

2015

Super Lawyer, Super Lawyers

2014

Super Lawyer, Super Lawyers

2013

Super Lawyer, Super Lawyers

2013

Recognition, Best Lawyers in America

2012

Super Lawyer, Super Lawyers

2012

Recognition, Best Lawyers in America

2012

Recognition, Oregon Super Lawyers

2011

Super Lawyer, Super Lawyers

2011

Recognition, Best Lawyers in America

2011

Recognition, Oregon Super Lawyers

2010

Recognition, Oregon Super Lawyers

2010

Super Lawyer, Super Lawyers

2010

Recognition, Best Lawyers in America

2009

Recognition, Oregon Super Lawyers

2009

Super Lawyer, Super Lawyers

2009

Recognition, Best Lawyers in America

2008

Recognition, Oregon Super Lawyers

2008

Super Lawyer, Super Lawyers

2008

Recognition, Best Lawyers in America

2007

Super Lawyer, Super Lawyers

2007

Recognition, Best Lawyers in America

2007

Recognition, Oregon Super Lawyers

2006

Recognition, Oregon Super Lawyers

2006

Super Lawyer, Super Lawyers

2006

Recognition, Best Lawyers in America

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Work Experience

2004 - Present

Shareholder, Lane Powell PC

1993 - 2004

Partner, Ball Janik LLP

1988 - 1993

Partner, Lee, Toomey & Kent

1984 - 1988

, Office of Tax Policy, U.S. Treasury Department

1981 - 1984

Associate, Peabody, Lambert & Meyers

1979 - 1981

Associate, Kirkland & Ellis

See All Work Experiences See Less Work Experiences

Associations

2006 - Present

Oregon State Bar, Taxation Section

Executive Committee, Member

2005 - Present

Oregon Business Association

Member, Business & Finance Committee

2004 - Present

Oregon Business Association

Member, Education Committee

2012 - 2012

Oregon State Bar, Taxation Section

Chair

2009 - 2010

Oregon Business Association

Chair, Education Committee

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Sample of Legal Cases

Metro One Telecommunications, Inc. v. Commissioner, 9th Cir. (2012), aff'g 135 T.C. 573 (2010)

See http://www.ca9.uscourts.gov/datastore/opinions/2012/12/19/11-70819.pdf

Hutchinson, et al. v. Commissioner, 166 T.C. 172 (2001)

See http://www.ustaxcourt.gov/InOpHistoric/Hutch2.TC.WPD.pdf

Abbott, et al. v. United States, 231 F.3d 889 (2d Cir. 2000), aff'g 76 F. Supp. 2d 236 (N.D.N.Y. 1999)

Summary judgment for United States

Abrahamsen, et al. v. United States, 228 F.3d 1360 (Fed. Cir. 2000), aff'g 44 Fed. Cl. 260 (1999)

Summary judgment for United States

ASARCO v. United States, 111 F.3d 10 (2d Cir. 1997), aff'g 96-2 USTC ¶50457 (S.D.N.Y. 1996)

Summary judgment for United States

Abramson Enterprises, Inc. v. Virgin Islands Bureau of Internal Revenue, cert. denied, 114 S. Ct. 441 (1994)

Cert. denied

Bizcap, Inc. v. Olive, 110 S. Ct. 2587 (1990)

Cert. denied

See More Legal Cases

Education

1979

Harvard University Law School

JD - Juris Doctor

1976

Vassar College

See All Education See Less Education

Speaking Engagements

2013

Oregon Financing Roundtable Conference Exploring New Markets Tax Credits in Oregon

2013

New Markets Tax Credit Conference True Debt Considerations – Leverage Loans and QLICIs

2012

Real Estate Conference

Taxation of Carried Interests

2012

New Markets Tax Credit Conference

Understanding Tax Consequences of the NMTC Put Option

2012

Mid-Valley Tax Forum

Partnership Tax Issues in Real Estate Joint Ventures

2011

Third Annual Solar Power Projects and Permitting Conference Policy and Incentives Update

2011

New Markets Tax Credit Conference

Reporting Considerations for Troubled Debt

2011

11th Annual Oregon Tax Institute Codification of the Economic Substance Doctrine — The Impact on Tax Practice

2010

Solar Power Conference

Federal Incentives for Solar Energy

2010

Real Estate Joint Ventures, Current Challenges, Strategies and Opportunities Maximizing the Bottom Line: Working Through the Partnership Tax Issues

2010

New Markets Tax Credit Conference

New Markets Tax Credits - Back-End Structuring

2010

Future Energy Conference

Energy Project Financing Fundamentals

2010

Financing Renewable Energy Conference

Combining the Subsidies – Twinning PTC, ITC or Treasury Grants with New Markets Tax Credits

2009

Tax Section Luncheon Series

Return Preparer Penalties and Circular 230 – Selected Topics for Tax Advisors

2009

New Treasury Guidance for Grants in Lieu of Tax Credits, Leveraging the New Option for Financing Renewable Energy Projects

Treasury Guidance for Cash Grants in Lieu of Tax Credits Under Section 1603 of the American Recovery and Reinvestment Act of 2009

2008

Renewable Energy Conference

Rebates, RETCs, State Tax Credits & More

2008

Oregon/Washington Tax Institute

Written Federal Tax Advice - Regulation and Risks

2008

OLI Conference - Going Green: Advising Clients in the New World of Sustainability

Monetizing Tax Credits

2007

Oregon Society of CPAs - Real Estate Conference

Reading Partnership and LLC Agreements

2007

Oregon Society of CPAs - Accounting & Auditing Conference

Making Sense of FIN 48

2007

Lane Powell/KPMG Joint Seminar

FIN 48 Reality Check: Compliance in the Real World

2006

Strafford Tax CPE Briefings

FIN 48 Compliance: Are you Ready? New Accounting Methods For Uncertain Income Tax Positions

2006

New Markets Tax Credit Investors Conference

New Markets Tax Credits Basics

2005

Oregon Tax Institute

Federal Income Taxation - Selected Recent Developments

1997

NYU Institute on Federal Taxation

Tax Treatment of Employment-Related Damages, Settlement Agreements, and Early Retirement Incentive Payments

1996

NYU Institute on Federal Taxation

Recent Developments in the Income Tax Treatment of Employment-Related Damages

1994

NYU Institute on Federal Taxation

Corporate Alternative Minimum Tax

1990

NYU Institute on Federal Taxation

Application of the New Section 469 Regulations in a Real Estate Development Scenario

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Publications

2012

Practical Tax Strategies Recent U.S. Tax Court Decision Highlights Issues Regarding the Tax Treatment of Damages for Stress-Induced Physical Ailments

2011

Novogradac Journal of Tax Credits Managing the Exit Tax Burden of the QALICB - Part I

2011

Novogradac Journal of Tax Credits Managing the Exit Tax Burden of the QALICB - Part II

2010

Journal of Taxation Grants in Lieu of Tax Credits Under the Recovery Act–A Square Peg in a Round Hole

2009

Oregon State Bar Taxation Section Newsletter Hit the Road, Jack – And Don’t You Pay [Oregon] Tax No More?

2008

Portland Business Journal New Rules Put Pressure on Private Companies

2008

Oregon State Bar Taxation Section Newsletter The Oregon Business Energy Tax Credit

2007

Tax Notes Textron, the Work Product Doctrine, and the Impact of FIN 48

2006

Tax Notes FIN 48: Measuring Tax Benefits in The Real World

2006

The Tax Executive Accounting for Uncertainty in Income Taxes -- The Effect of FASB Interpretation No. 48

2005

BUILDERnews Magazine Critical Planning Points in Real Estate Partnerships and Joint Ventures

2005

BUILDERnews Magazine The Devil is in the Details - New Tax Deduction for Construction Businesses

1995

Prentice Hall Law & Business Taxation of Passive Activities (3 volumes)

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