Case Review
Business
Advise on acquisition of private aircraft with emphasis on minimizing state and local taxation on acquisition and operation of aircraft
Sports Business
Advise professional athlete on strategies in structuring business entity to minimize state and location taxation
Technology
Advise internet services company from start-up through sale, including particular attention to entity formation, sweat equity to key employees, and sale of company to Silicon Valley purchaser, including negotiation and documenting acquisition transaction and various restrictive covenants and employment agreements
Executive Compensation
Represent CEO candidate in hiring negotiations for large company, including negotiation and drafting of employment agreement, equity based compensation, and various restrictive covenants
Technology
Advise telecommunications company on national state and local tax implications of business formation and selection of location venue, including in-depth analysis and strategies on taxation of telecommunications and internet-based services by various state and municipal governments
Tax Controversy
Represent investors in large, hotly contested tax motivated investment (commonly know as a tax shelter) before the IRS
Food Services
Represent restaurant company as consulting general counsel with respect to various corporate and business issues, including expansion of restaurant locations, planning to minimize state franchise tax; organizing ownership of intellectual property incident to operation of business; advise on buy-out of minority partners
Tax Controversy
Represent taxpayer in seeking claim for refund and in subsequent litigation to obtain refund of penalties imposed by IRS in tax motivated investment
Estate Planning
Represent large, multi-generational agricultural based business family in an in-depth estate plan, including long-term dynasty trusts, family partnerships, private foundation and valuation issues
Criminal Tax
Served as tax counsel in advising taxpayers involved in allegations of failure to file returns and report income
Tax Controversy
Represent financial institution in challenges by IRS for failure of financial institution to comply with IRS levy
Executive Compensation
Advise top executives of financial institutions on issues involving tax and creditors’ rights issues involved in various funding and unfunded deferred compensation arrangements
Corporate Merger and Sale
Advised controlling group of community bank on strategies to prepare for sale of bank and formation of ESOP
Estate Planning
Advised multi-generation ranching family on estate planning issues arising from extensive holdings of ranch land through western U.S.
Corporate Asset Purchase
Represented manufacturing and technical services company on purchase of key technology and manufacturing processes for aviation industry, including negotiation and documenting of purchase and sale transaction, restrictive covenants
Corporate
Acted as consulting general counsel in advising technology company on forming and operating a large scale direct sales organization
Corporate
Represented estate of owner and operator of motels, with particular attention given to preparation and planning for estate tax return, negotiation of various creditors’ claims, including secured lenders
Probate
Represented estate of CEO of financial institution dying intestate
International Tax
Advised US resident in international business on international tax issues arising from retirement from employment, including issues of foreign withholding, drafting deferred compensation and severance arrangements
Corporation Merger and Sale
Represented and advised owner of wholesale building products on sale of company, including issues involving (1) uncooperative spouse of owner, (2) utilizing Chapter 11 proceeding to gain approval of sale, and (3) secured lenders
Tax Controversy
Represented and advised publicly held US based technology company on issues arising from aggravated IRS audit examination, including IRS summons
Tax Controversy
Represented widow in IRS litigation involving widow’s separate property rights
Attorney and Counselor