"A dean of the tax controversy Bar, revered for his 'spectacular courtroom manner and skills.'"
Chambers USA 2010

Übersicht

Joel Williamson is widely acknowledged as one of the nation's leading tax attorneys and litigators. He has litigated over 60 tax cases. His unprecedented experience includes the trial of seven major IRC 482 transfer pricing cases, including Eli Lilly, G.D. Searle, Westreco (Nestlé), Seagate Technology, National Semiconductor, United Parcel Service and Eaton Corporation. Eaton, which also involved the cancellation of two Advanced Pricing Agreements, was decided by the US Tax Court on July 26, 2017, and resulted in a rare 100% transfer pricing taxpayer victory. Recently, Joel served as trial counsel in the Guidant LLC and Eaton cases, each involving IRC 482 issues. Joel has also litigated numerous cases involving economic substance of transactions, including the United Parcel Service case noted above, as well as the Saba Partnership (Brunswick) case, and Mukerji (Comdisco), an important test case for tax-advantaged computer leasing transactions involving Comdisco. More recently, Joel litigated ConEd which involved an international Lease-In-Lease-Out transaction and Flextronics which involved an international merger and acquisition transaction. Both ConEd and Flextronics witnessed IRS arguments of economic substance and generic tax doctrines including substance over form and step transaction. Recently, Joel litigated Exelon which involved a like-exchange of utility assets that the IRS challenged on economic substance and substance over form grounds.

In the international tax area, Joel has litigated Subpart F, constructive triangular dividend, R&D Moratorium, Brazilian and other foreign tax credit for banks, including Bankers Trust and Riggs Bank, as well as Iranian loss investment in U.S. property (IRC 956) and foreign-versus-domestic-source income (IRC 863(b)) questions. He has litigated two significant captive insurance cases involving Humana, Inc. and Gulf Oil Corporation. In addition, Joel has litigated IRC 338 corporate acquisition related issues, including goodwill, intangible and inventory valuations and second-tier allocations involving Nestlé's acquisition of Carnation.

Joel litigated the Tribune Company case, which dealt with whether a divestiture of a subsidiary qualified as a tax-free corporate reorganization. He has litigated significant tax accounting issues, including unbilled revenue and cap interest rate loan questions. Joel has also litigated significant procedural questions, including the proper role of IRS trial counsel in the audit examination process. He is also experienced in summons enforcement actions for both foreign and domestic records. 

Chambers, a leading professional directory, consistently recognizes Joel as "a dean of the tax Bar" and an industry leader. Chambers USA has praised Joel throughout the year as:

  • "Absolutely superb."
  • "A top-notch litigator; he has a lot of experience in significant tax cases and helps to manage our expectations; he couldn't do any better." Among his many honors, he is known as "the godfather of transfer pricing litigation."
  • A "fantastic individual" and adding: "If you know the IRS is going to go to the net and alternative dispute resolution is not attainable, you want Joel on your side."
  • "Joel is one of the most successful controversy attorneys in the USA...his experience is almost unrivaled...[he is an] 'obvious standout' in the national tax market...[and is] 'especially adept at arguing the most technical issues.'"
  • "'Probably has more experience in litigating cases than any lawyer in the USA'...'enormous presence and stature' [with] 'long history with transfer pricing litigation'"
  • "Leading light"
  • "Great strategist and tactician" who "takes the role of service provider very seriously"
  • "A dean of the tax controversy Bar, revered for his 'spectacular courtroom manner and skills'"
  • "Unparalleled battleground experience"
  • "Constantly on top of his game"
  • "Exhaustive preparation"
  • "Fearless and tireless"
  • "Much admired in the profession for his ability to identify the issues at hand quickly and incisively"

Joel is proud to have been recognized by Chambers USA as: "Leading Lawyers," 2003-2004, 2004, 2005, 2006, 2007, 2008, 2009, 2010, 2011, 2012, 2013, 2014, 2015, 2016, 2017 and 2018. In addition, he was recognized by Legal 500 as a "Leading Lawyer" in 2008, 2011, 2012, 2013, 2014, 2015 and 2016, describing Joel as a, "highly skilled trial attorney possessing great judgment." In 2017, Joel was inducted into The Legal500 Hall of Fame which highlights individuals who have received constant praise by their clients for continued excellence. He is also further recognized as a leading Tax Controversy adviser in the 2012, 2013, 2015 and 2016 International Tax Review "Tax Controversy Leaders Guide," as well as a leading Transfer Pricing advisor in Expert Guides "The Best of the Best USA 2013 - Transfer Pricing." Joel was also named "2015 Tax Litigation Attorney of the Year" by ACQ

Joel served as an officer in the United States Army from 1970 to 1972, assigned to the Offices of the Staff Judge Advocate, 12th Support Brigade, Ft. Bragg, NC, and subsequently to Saigon Support Command, the Republic of South Vietnam. After his return from Vietnam in 1972, Joel joined the Chief Counsel's Office, US Department of Treasury. In 1978, he was appointed one of 20 Special Trial Attorneys located throughout the United States. Joel joined Mayer Brown in 1986 and was named partner that same year.

Sprachkenntnisse

  • Englisch
Highlights
Tax Controversy Team of the Year

Erfahrung

  • Hyatt Hotels Corporation & Subsidiaries v. Commissioner of Internal Revenue, T.C. Docket No. 013858-17 (tax treatment of customer loyalty program).
  • Cross Refined Coal, LLC, USA Refined Coal LLC, Tax Matters Partner v. Commissioner of Internal Revenue, T.C. Docket No. 019502-17 (tax treatment of refined coal partnership).
  • EOG Resources, Inc. & Subsidiaries v. Commissioner of Internal Revenue, T.C. Docket No. 012794-17 (alternative minimum tax preference for intangible drilling costs).
  • Tribune Media Company F.K.A. Tribune Company & Affiliates v. Commissioner of Internal Revenue, T.C. Docket No. 20940-16 (tax treatment of leveraged partnership transaction).
  • Chicago Baseball Holdings, LLC, Northside Entertainment Holdings, LLC, F.K.A. Ricketts Acquisition, LLC, Tax Matters Partner v. Commissioner of Internal Revenue, T.C. Docket No. 20941-16 (tax treatment of leveraged partnership transaction).
  • Eaton Corporation v. Commissioner (T.C. Memo 2017-147) (IRC § 482 reallocations and the cancelation of advance pricing agreements; tried in August/September 2015).
  • United States v. Eaton Corporation, 1:13-mc-102, 1:13-mc-111, 1:13-mc-112 (N.D. Ohio 2014); 2:13-cv-01825 (W.D. Pa. 2014); 3:13-cv-01956 (D.P.R. 2014) (summons enforcement litigation).
  • Eaton Corporation v. Commissioner, 140 T.C. 410 (2013) (abuse of discretion standard applies to advanced pricing agreement cancellation).
  • United States v. Eaton Corporation, 1:12 MC 24, 1:12 MC 25, 1:12 MC 26, 1:12 MC 27, 2012 WL 3486910 (N.D. Ohio Aug. 15, 2012) (summons enforcement litigation).
  • Exelon Corporation v. Commissioner of Internal Revenue, T.C. Docket Nos. 029183-13 and 029184-13 (tax treatment of $1.3 billion like-kind exchange of utility assets; tried in August 2015). 147 T.C. No. 9 (2016).
  • Tyco Electronics Corp., formerly known as AMP, Inc., & Subsidiaries v. Commissioner of Internal Revenue, T.C. Docket No. 16654-13 (decision entered May 31, 2016) (debt-equity characterization).
  • Covidien LP, f.k.a. Tyco Healthcare Group, LP, Covidien Holding Inc., f.k.a. SWD Holding, Inc. I, Tax Matters Partner v. Commissioner of Internal Revenue, T.C. Docket No. 16663-13 (decision entered May 31, 2016) (debt-equity characterization).
  • Tyco Electronics Corporate Holdings, Inc., as successor in interest to Tyco Holdings, Inc. & Subsidiaries v. Commissioner of Internal Revenue, T.C. Docket No. 16661-13 (decision entered May 31, 2016) (debt-equity characterization).
  • Tyco Electronics Corp., as successor in interest to Tyco International (PA), Inc. & Subsidiaries v. Commissioner of Internal Revenue, T.C. Docket No. 16659-13 (decision entered on May 31, 2016) (debt-equity characterization).
  • Tyco Electronics Corp., as successor in interest to TSSL Holding Corp. & Subsidiaries v. Commissioner of Internal Revenue, T.C. Docket No. 16655-13 (decision entered May 31, 2016) (debt-equity characterization).
  • Tyco Electronics Corporate Holdings, Inc., as successor in interest to Tyco (US) Holdings, Inc. & Subsidiaries v. Commissioner of Internal Revenue, T.C. Docket No. 16658-13 (decision entered May 31, 2016) (debt-equity characterization).
  • Tyco Electronics Corp., as successor in interest to Tycom (US) Holdings, Inc. & Subsidiaries v. Commissioner of Internal Revenue, T.C. Docket No. 16662-13 (decision entered May 31, 2016) (debt-equity characterization).
  • Tyco Electronics Corp., as successor in interest to Tycom Simplex Holdings, Inc. & Subsidiaries v. Commissioner of Internal Revenue, T.C. Docket No. 16651-13 (decision entered May 31, 2016) (debt-equity characterization).
  • United States Surgical Corporate & Subsidiaries v. Commissioner of Internal Revenue, T.C. Docket No. 16664-13 (decision entered May 31, 2016) (debt-equity characterization).
  • ADT Holdings, Inc.v. Commissioner of Internal Revenue,T.C. Docket No. 16656-13 (decision entered May 31, 2016) (Withholding Tax).
  • Sherwood Medical Company I v. Commissioner of Internal Revenue, T.C. Docket No. 16652-13 (decision entered May 31, 2016) (Withholding Tax).
  • Covidien Group S.A.R.L., f/k/a Tyco Group S.A.R.L. v. Commissioner of Internal Revenue, T.C. Docket No. 16653-13 (decision entered May 31, 2016)(Withholding Tax).
  • Tyco Electronics Corp., as successor in interest to Tyco International (PA), Inc. v. Commissioner of Internal Revenue, T.C. Docket No. 16657-13 (decision entered May 31, 2016) (Withholding Tax).
  • Tyco Electronics Corporate Holdings, Inc., as successor in interest to Tyco (US) Holdings, Inc. v. Commissioner of Internal Revenue, T.C. Docket No. 16660-13 (decision entered May 31, 2016) (Withholding Tax).
  • Guidant LLC v. Commissioner of Internal Revenue, T.C. Docket No. 5501-12 (IRC 482 reallocations). 146 T.C. 60 (2016).
  • Cardiac Pacemakers, Inc. v. Commissioner of Internal Revenue, T.C. Docket No. 5502-12 (IRC 482 reallocations)
  • Boston Scientific Corporation v. Commissioner of Internal Revenue, T.C. Docket No. 26876-11 (IRC 482 reallocations)
  • Guidant LLC v. Commissioner of Internal Revenue, T.C. Docket No. 5989-11 (IRC 482 reallocations)
  • Cardiac Pacemakers, Inc. v. Commissioner of Internal Revenue, T.C. Docket No. 5990-11 (IRC 482 reallocations)
  • Cardiac Pacemakers, Inc. v Commissioner of Internal Revenue, T.C. Docket No. 10985-11 (IRC 367 allocations)
  • Consolidated Edison Co. of N.Y., Inc. & Subsidiaries v. United States, 2013 WL 93110 (Fed. Cir. Jan. 9, 2013), rev'g 90 Fed. Cl. 228 (2009) (recharacterizing lease-in lease-out ("LILO") transaction under substance over form doctrine).
  • Flextronics America, as Alternative Agent for C-Mac Holdings, Inc. and Subsidiaries Consolidated Group, Petitioner-Appellee v. Commissioner of Internal Revenue,Respondent-Appellant. 499 Fed.Appx. 725 (9th Cir. 2012) aff'g T.C. Memo 2010-245.
  • Flextronics America, LLC, as Alternative Agent Pursuant to Treas. Reg. 1.1502-77A(e)(4)(ii) for C-MAC Holdings, Inc. & Subsidiaries Consolidated Group v. Commissioner of Internal Revenue, T.C. Memo 2010-245 (basis in acquired inventory).
  • Amergen Energy Co., LLC, by and through Exelon Generation Co., LLC, Tax Matters Partner v. The United States, 94 Fed.Cl. 413, (2010) (opinion on discovery motion to compel admissions). For an article analyzing the Court's decision see Jasper L. Cummings, Jr., "Capitalization: Selling Nuclear Decommissioning Funds", Daily Tax Report, (10/12/2010).
  • Wells Fargo & Company v. United States, 105 A.F.T.R.2d 2010-377 (Ct. Fed. Cl., Jan. 8, 2010), (denying deductions for leveraged leases of transit equipment and technical equipment), aff'd 641 F.3d 1319 (Fed Cir. 2011).
  • Brunswick Corporation & Subsidiaries v. United States of America, US District Court, Northern District of Illinois, Docket No. 07C 3792, (basis for depreciation in an I.R.C. 338 acquisition transaction).
  • Tribune Company v. Commissioner of Internal Revenue, 125 T.C. 110 (2005), (holding that the divestiture of Bender was a taxable sale and not a tax-free reorganization).
  • Saba Partnership, Brunswick Corporation, Tax Matters Partner, et al. v. Commissioner of Internal Revenue, 78 T.C.M. (CCH) 684 (1999), vacated by 273 F.3d 1135 (DC Cir. 2001), remanded to 85 T.C.M. (CCH) 817 (2003) (challenge to investment partnerships as devoid of economic substance).
  • The Boeing Company and Consolidated Subsidiaries v. United States of America, 123 S.Ct. 1099 (2003) (allocation of R&D costs in determination of sales income under DISC and FSC rules).
  • PNC Financial Services Group, Inc. v. Commissioner of Internal Revenue (formerly Riggs National Corp. v. Commissioner of Internal Revenue) , 503 F.3d 119 (D.C. Cir. 2007), aff'g, T.C. Memo. 2004-110, 87 T.C.M. (CCH) 1276 (2004) ("Riggs III"), on remand from 295 F.3d 16 (D.C. Cir. 2002), rev'g and remanding T. C. Memo. 2001-12, 81 T.C.M. (CCH) 1023 (2001) ("Riggs II"), on remand from 163 F.3d 1363 (D.C. Cir. 1999), rev'g and remanding 107 T.C. 301 (1996) ("Riggs I") (holding that official tax receipts of Brazilian government were entitled to evidentiary presumption).
  • The Limited, Inc. v. Commissioner of Internal Revenue, 286 F.3d 324 (6th Cir. 2002), rev'g, 113 T.C. 169 (1999)(reversing the Tax Court's holding that CFC's purchase of CDs from affiliated credit card bank failed to quality as 956(b)(2)(A) "deposits with [a] person "carrying on banking business.").
  • The Boeing Company and Consolidated Subsidiaries, and Boeing Sales Corporation v. United States of America, 258 F.3d 958, (9th Cir. 2001) (allocation of R&D costs in determination of sales income under DISC and FSC rules) (petition for panel rehearing and rehearing en banc).
  • United Parcel Service of America v. Commissioner of Internal Revenue, 254 F.3d 1014 (11th Cir. 2001), rev'g and remanding, T.C. Memo. 1999-268, 78 T.C.M. (CCH) 262 (1999) (vacating Tax Court's finding on sham, assignment of income and penalties).
  • Bankers Trust New York Corporation v. United States, 36 Fed. Cl. 30 (1996), rev'd and remanded, 225 F.3d 1368 (Fed. Cir. 2000) (Brazilian foreign tax credits).
  • The Limited, Inc. v. Commissioner of Internal Revenue, 113 T.C. 169 (1999) (Subpart F, IRC 956 "banking exception").
  • United Parcel Service of America v. Commissioner of Internal Revenue, T.C. Memo. 1999-268, 78 T.C.M. (CCH) 262 (1999) (sham transaction and IRC 61, 482 and 845 reallocations).
  • Intel Corporation v. Commissioner of Internal Revenue, 111 T.C. 90 (1998) (imposition of statutory interest on deficiencies offset by foreign tax credit carrybacks).
  • Nestlé Holdings, Inc. v. Commissioner of Internal Revenue, 152 F.3d 83 (2d Cir. 1998); rev'g and remanding, T.C. Memo. 1995-441, 70 T.C.M. (CCH) 682 (1995) (Carnation acquisition, valuation of trademarks).
  • Overseas Partners Ltd. v. Commissioner of Internal Revenue, T.C. Docket No. 15966-95 (engaged in business issues arising under IRC 882 and 842) (conceded by IRS).
  • Intel Corporation v. Commissioner of Internal Revenue, 76 F.3d 976 (9th Cir. 1995) (source of export income).
  • Nestlé Holdings, Inc. v. Commissioner of Internal Revenue, T.C. Memo. 1995-441, 70 T.C.M. (CCH) 682 (1995) (IRC 482 reallocations, Carnation acquisition).
  • Nabisco Brands, Inc. (RJR) v. Commissioner of Internal Revenue, T.C. Memo. 1995-127, 69 T.C.M. (CCH) 2230 (1995) (amortization of trademarks pursuant to IRC 1253).
  • Cline v. Commissioner of Internal Revenue, 34 F.3d 480 (7th Cir. 1994) (golden parachute payments).
  • Norwest Corporation and Affiliated Companies v. Commissioner of Internal Revenue, 69 F.3d 1404 (8th Cir. 1995), cert. denied, 116 S. Ct. 1704 (1996) (Brazilian foreign tax credits).
  • National Semiconductor Corporation v. Commissioner of Internal Revenue, T.C. Memo. 1994-195, 67 T.C.M. (CCH) 2849 (1994), acq. in result, 1995-2 C.B.1 (IRC 482 reallocations).
  • Seagate Technology, Inc. v. Commissioner of Internal Revenue, 102 T.C. 149 (1994) (IRC 482 reallocations).
  • Continental Illinois Corporation v. Commissioner of Internal Revenue, 501 US 1041 (1994) (recognition of income on CAP loans) (denying petition for certiorari).
  • Sara Lee Corporation and Subsidiaries v. United States, 29 Fed. Cl. 330 (1993) (use of Revenue Agent's Report as evidence supporting audit adjustments).
  • Intel Corporation v. Commissioner of Internal Revenue, 100 T.C. 616 (1993), aff'd, 67 F.3d 1445 (9th Cir. 1995) (allocation of income partly from sources within a foreign country under Treas. Reg. 1.863-3(b)(2)).
  • Continental Illinois Corporation v. Commissioner of Internal Revenue, 998 F.2d 513 (7th Cir. 1993), cert. denied, 510 US 1041 (1994) (Brazilian foreign tax credits, foreign tax credits relating to net quoted loans, and recognition of income on CAP loans).
  • Westreco, Inc. (Nestlé) v. Commissioner of Internal Revenue, T.C. Memo. 1992-561, 64 T.C.M. (CCH) 849 (1992) (allocation of income between foreign parent corporation and US subsidiary).
  • National Semiconductor Corporation v. Commissioner of Internal Revenue, T.C. Memo. 1991-81, 61 T.C.M. (CCH) 2005 (1991) (burden of proof in IRC 482 case).
  • Continental Illinois Corporation v. Commissioner of Internal Revenue, T.C. Memo. 1991-61, 61 T.C.M. (CCH) 1916 (1991) (foreign tax credits relating to net quoted loans).
  • Westreco, Inc. (Nestlé) v. Commissioner of Internal Revenue, 923 F.2d 855 (6th Cir. 1991) (appeal dismissed and writ of mandamus denied).
  • Westreco, Inc. (Nestlé) v. Commissioner of Internal Revenue, T.C. Memo. 1990-501, 60 T.C.M. (CCH) 824 (1990) (protective order restricting IRS use of summons in the Tax Court).
  • Nestlé Holdings, Inc. v. Commissioner of Internal Revenue, 94 T.C. 803 (1990) (calculation of amount in receipt of preferred stock for property).
  • Continental Illinois Corporation v. Commissioner of Internal Revenue, 94 T.C. 165 (1990) (Iranian loss issues).
  • Continental Illinois Corporation v. Commissioner of Internal Revenue, T.C. Memo. 1989-636, 58 T.C.M. (CCH) 790 (1989) (recognition of income on CAP loans).
  • Continental Illinois Corporation v. Commissioner of Internal Revenue, T.C. Memo. 1989-468, 57 T.C.M. (CCH) 1464 (1989) (evidentiary issues relating to substantiation of foreign tax credits).
  • Continental Illinois Corporation and Citizens and Southern Corporation v. Commissioner of Internal Revenue, T.C. Memo. 1988-318, 55 T.C.M. (CCH) 1325 (1988) (Brazilian foreign tax credits).
  • Gulf Oil Corporation v. Commissioner of Internal Revenue, 89 T.C. 1010 (1987), aff'd, 914 F.2d 396 (3d Cir. 1990) (deductibility of insurance premiums paid to captive insurer).
  • Consumers Power Co. v. Commissioner of Internal Revenue, 89 T.C. 710 (1987) (method of accounting and time of placement in service for depreciation and investment credit purposes).
  • Veterans of Foreign Wars v. Commissioner of Internal Revenue, 89 T.C. 7 (1987) (unrelated business income).
  • G.D. Searle & Co. v. Commissioner of Internal Revenue, 88 T.C. 252 (1987) (allocation of income and deductions among related taxpayers).
  • Humana, Inc. v. Commissioner of Internal Revenue, 88 T.C. 197 (1987), aff'd in part, rev'd in part, 881 F.2d 247 (6th Cir. 1989) (deductibility of insurance premiums paid to captive insurer).
  • Mukerji (Comdisco, Inc.) v. Commissioner of Internal Revenue, 87 T.C. 926 (1986) (deductibility of expenses related to computer leasing).
  • Gulf Oil Corporation v. Commissioner of Internal Revenue, 87 T.C. 548 (1986) (956 investment in US property and constructive dividends).
  • Eli Lilly & Co. v. Commissioner of Internal Revenue, 84 T.C. 996 (1985), aff'd in part, rev'd in part, 856 F.2d 855 (7th Cir. 1988) (allocation of income and deductions among related taxpayers).
  • Humana, Inc. v. Commissioner of Internal Revenue, T.C. Memo. 1985-426, 50 T.C.M. (CCH) 784 (1985), on reconsideration to 88 T.C. 197 (1987), aff'd in part, rev'd in part, 881 F.2d 247 (6th Cir. 1989) (deductibility of insurance premiums paid to captive insurer).
  • Simmons v. Commissioner of Internal Revenue, 73 T.C. 1009 (1980) (government's affirmative proof of fraud where allegations are only denied by taxpayer).
  • Community Research & Development Corporation v. Commissioner of Internal Revenue, T.C. Memo. 1979-264, 38 T.C.M. (CCH) 1043 (1979) (bad debt deduction).
  • Duley v. Commissioner of Internal Revenue, T.C. Memo. 1979-264, 38 T.C.M. (CCH) 1035 (1979) (deductibility of travel expense).
  • Smith v. Commissioner of Internal Revenue, T.C. Memo. 1979-260, 38 T.C.M. (CCH) 1030 (1979) (deductibility of travel expense).
  • Phillips v. Commissioner of Internal Revenue, T.C. Memo. 1979-258, 38 T.C.M. (CCH) 1027 (1979) (deductibility of travel expense).
  • Hurst v. Commissioner of Internal Revenue, T.C. Memo. 1979-232, 38 T.C.M. (CCH) 924 (1979) (deductibility of travel expense).
  • Thacker v. Commissioner of Internal Revenue, T.C. Memo. 1979-231, 38 T.C.M. (CCH) 923 (1979) (deductibility of travel expense).
  • Kirk v. Commissioner of Internal Revenue, T.C. Memo. 1979-135, 38 T.C.M. (CCH) 598 (1979) (deductibility of travel expense).
  • Galloway v. Commissioner of Internal Revenue, T.C. Memo. 1979-134, 38 T.C.M. (CCH) 596 (1979) (deductibility of travel expense).
  • Hill v. Commissioner of Internal Revenue, T.C. Memo. 1979-133, 38 T.C.M. (CCH) 595 (1979) (income averaging).
  • Wilcox Manufacturing Co., Inc. v. Commissioner of Internal Revenue, Orelite Manufacturing Co., Inc. v. Commissioner of Internal Revenue, T.C. Memo. 1979-92, 38 T.C.M. (CCH) 378 (1979) (accumulated earnings tax).
  • Sexton v. Commissioner of Internal Revenue, T.C. Memo. 1979-31, 38 T.C.M. (CCH) 340 (1979) (substantiation of interest deduction).
  • Silman v. Commissioner of Internal Revenue, T.C. Memo. 1978-266, 37 T.C.M. (CCH) 1146 (1978), appeal dismissed, 586 F.2d 838 (4th Cir. 1978), cert. denied, 440 US 920 (1979) (constitutionality of the federal income tax).
  • McCallister v. Commissioner of Internal Revenue, 70 T.C. 505 (1978) (deductibility of travel expense).
  • Hensley v. Commissioner of Internal Revenue, T.C. Memo. 1978-242, 37 T.C.M. (CCH) 1043 (1978) (deductibility of travel expense).
  • Harrison v. Commissioner of Internal Revenue, T.C. Memo. 1978-241, 37 T.C.M. (CCH) 1041 (1978) (deductibility of travel expense).
  • Uhlenbrock v. Commissioner of Internal Revenue, 67 T.C. 818 (1977) (penalty as ordinary and necessary business expense).
  • Wallace v. Commissioner of Internal Revenue, T.C. Memo. 1976-219, 35 T.C.M. (CCH) 954 (1976) (ability of Commissioner to use net worth computation).
  • Sherry v. Commissioner of Internal Revenue, T.C. Memo. 1975-337, 34 T.C.M. (CCH) 1468 (1975) (ordinary and necessary business expenses).

Ausbildung

Davidson College, BA

University of Kentucky College of Law, JD

Order of the CoifUniversity of Kentucky Law Review; Moot Court Board; National Moot Court Team

Zulassung

Bar

  • Illinois
  • Kentucky

Gericht

  • US Supreme Court
  • US Court of Federal Claims
  • US Court of Appeals for the Federal Circuit
  • US Court of Appeals for the Second Circuit
  • US Court of Appeals for the Sixth Circuit
  • US Court of Appeals for the Seventh Circuit
  • US Court of Appeals for the Eighth Circuit
  • US Court of Appeals for the Ninth Circuit
  • US Court of Appeals for the Eleventh Circuit
  • US Court of Appeals for the District of Columbia Circuit
  • US Court of Federal Claims
  • US District Court for the Northern District of Illinois
  • US District Court for the Northern District of Ohio
  • US District Court for the Western District of Pennsylvania
  • Illinois Supreme Court
  • US Tax Court
  • Trial Bar of the US District Court for the Northern District of Illinois

Berufliche Aktivitäten

  • Board of Trustees, Davidson College
  • Board of Visitors, Davidson College
  • Kentucky Bar Association
  • United States District Court Trial Bar, Northern District, Illinois
  • American Bar Association
  • The American Club of Paris
  • The Chicago Club
  • The Joffrey Ballet, Inc.
  • Board of Directors, The Joffrey Ballet, Inc.