Representative Legal Matters
Representing Sunoco, Inc. in a suit challenging the offset of the ethanol fuel credit to cost of goods sold.
Represented several Category 2, Category 3, and non-participating banks with respect to the DOJ non-prosecution agreement program including advising on foreign law deductibility of payments made.
Representing an individual in a major securities fraud investigation.
Lead counsel in a case to compel the President of the United States to comply with Federal record-keeping laws.
Representing a major pharmaceutical company in a transfer pricing dispute with the IRS.
Represented the former General Counsel of the Navy in amicus briefs in the Supreme Court and the Fourth Circuit setting out the policy and ethical justifications barring the use of torture.
Defended Shell Oil Company in a period of limitations case in the Federal Circuit.
Tried Tax Equity and Fiscal Responsibility Act (TEFRA), period of limitations, and economic substance issues before the United States Tax Court for former partners of BCP Trading & Investments, LLC.
Represented a key witness in a major tax evasion investigation by DOJ.
Represented Guardian Industries Corporation in a successful motion for summary judgment, affirmed on appeal, regarding foreign tax credit and technical taxpayer issues.
- Leading individual in Tax Controversy, Legal 500, 2009-2015
- Recommended Lawyer, ITR – World Tax 2014
- Leading Lawyer, ITR Tax Controversies 2014
- Recognized in White Collar Crime, Super Lawyers (Washington DC) 2013-2014
- U.S. District Court, Southern District of Texas~United States (2017)
- U.S. Court of Appeals, Second Circuit~United States (2017)
- U.S. Court of Appeals, Fifth Circuit~United States (2016)
- U.S. District Court, Eastern District of Virginia~United States (2008)
- U.S. Supreme Court~United States (2007)
- U.S. Court of Appeals for the Armed Forces~United States (2006)
- U.S. Court of Appeals, District of Columbia Circuit~United States (2006)
- U.S. District Court, District of Columbia~United States (2006)
- U.S. District Court, District of Maryland~United States (2006)
- U.S. Court of Appeals, Federal Circuit~United States (2005)
- District of Columbia~United States (2005)
- U.S. Court of Appeals, Fourth Circuit~United States (2004)
- Virginia~United States (2004)
- U.S. Court of Federal Claims~United States (2004)
- U.S. Tax Court~United States (2004)
- Georgetown University Law Center (J.D., magna cum laude) (2003)
- Edgewood College (B.S. Accounting, magna cum laude) (1998)
- Author, "When the Wall Comes Crumbling Down: What to Do With Taxpayers Who Cannot or Will Not Voluntarily Disclose," BNA Daily Report for Executives, December 2011
- Author, "Whistleblowers: Latest Danger to Privilege, Work Product in Tax Department," BNA Daily Report for Executives, October 2011
- Author, "Be Careful Taking Five in the Ninth," Forbes IRS Watch Blog, September 2011
- Author, "Willful Failure to File FBARs and the Sergeant Schultz Defense," BNA Daily Tax Report, August 2011
- Author, "IRS Takes Next Steps in International Realignment," Practical International Tax Strategies, June 2011