Marjorie Margolies has been an effective advocate for taxpayers at all levels of federal tax controversy since joining the firm in 1988.
She also focuses on negotiating and documenting agreements at the Exam, Appeals, and litigation levels through closing agreements, pre-filing agreements, stipulations of settlement, and decision documents on a wide variety of topics (transfer pricing, repatriation, credits and deductions, changes in method of accounting, and other timing issues, to name a few).
Margie has extensive experience in complex procedural and computational matters arising with respect to tax and interest litigation, refund claims, amended returns, and joint committee review, as well as the general payment and assessment system of the IRS.
Margie's foreign language capabilities include fluency in French and limited knowledge of Spanish. She is also a board Trustee of the non-profit HIPPY USA, a family literacy program.
Areas of Focus
Obtained a $440 million tax refund for HealthSouth due to the overpayment of tax as a result of fraudulent financial accounting.
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).
Intel Corporation v. Commissioner of Internal Revenue, 111 T.C. 90 (1998) (imposition of statutory interest on deficiencies offset by foreign tax credit carrybacks).
Seagate Technology, Inc. v. Commissioner of Internal Revenue, 102 T.C. 149 (1994) (I.R.C. § 482 reallocations).
Sara Lee Corporation and Subsidiaries v. United States, 29 Fed. Cl. 330 (1993) (use of Revenue Agent’s Report as evidence supporting audit adjustments).
May 20 – 212019
Foreign Tax Credit following TCJA,” ITR Leading Women in Tax Forum, New York, NY
Brown University, BA, magna cum laude
The University of Michigan Law School, JD
- US Tax Court
- US Supreme Court
- US District Court for the Northern District of Illinois
- US Court of Appeals for the Ninth Circuit
- US Court of Federal Claims
- NCJW-Milwaukee Section, Co-Vice President, Community Action