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TAX PROFILE/EXPERIENCE
SEPTEMBER 1993 TO DATE
PRIVATE PRACTICE OF TAX LAW
 
Engaged in the private practice of law with a heavy concentration on tax-implicated legal issues and controversies at both the State and Federal level.  Experience has included representing taxpayers at all levels of the IRS and state tax authorities and has included significant experience in matters relating to tax collection, audit and filing and reporting positions.  Audit experience includes returns with civil fraud and criminal tax exposure and significant tax liability exposure.  Tax advisory experience includes all areas of income, gift and estate tax laws and service to individuals, corporations, partnerships, limited liability companies, trusts, estates and other tax and non-tax professionals.  Authorized to practice before the IRS in all jurisdictions.  Authorized to practice generally (tax and other matters) in the State of  Rhode Island, State of Massachusetts, US Tax Court, US District Court, District of Rhode Island.
 
SEPTEMBER 1989 - SEPTEMBER 1993
TAX ATTORNEY, OFFICE OF THE CHIEF COUNSEL
INTERNAL REVENUE SERVICE
NATIONAL OFFICE WASHINGTON, DC
Multiple IRS Chief Counsel Special Act Award Recipient
 
SEPTEMBER 1988- SEPTEMBER 1989
SUPREME COURT OF RHODE ISLAND, JUDICIAL LAW CLERK TO SENIOR ASSOCIATE JUSTICE THOMAS F. KELLEHER
1988 GRADUATED WITH HONORS UNIVERSITY OF CONNECTICUT SCHOOL OF LAW
SEPTEMBER 1984- SEPTEMBER 1985, EMPLOYED AS MANUFACTURING ENGINEER
1984 GRADUATED UNIVERSITY OF RHODE ISLAND, B.S. ENGINEERING (IE) HIGH HONORS (NUMBER 2 RANK IN CLASS—TAU BETA PI ENGINEERING HONOR SOCIETY)

TAXATION

 

PARTNERSHIPS

 

LIMITED LIABILITY COMPANIES

 

CORPORATIONS

 

  TRUSTS & ESTATES

 

INDIVIDUALS

 

 

TAX LEGISLATION

 

  DEVELOPMENT AND DRAFTING OF TAX LEGISLATION HANDLED CONGRESSIONAL TAX INQUIRIES ON BEHALF OF THE IRS


WORKED WITH

 

 IRS CHIEF COUNSEL

 

DISTRICT COUNSEL,

 

DISTRICT DIRECTOR

 

ON COMPLEX MATTERS OF TAX

 

 REGULATION,

 

COMPLIANCE

 

 ENFORCEMENT

 

AUDIT

 

 LITIGATION

 

AUTHORED AND PUBLISHED: TAX REGULATIONS; IRS  REVENUE RULINGS; IRS REVENUE  PROCEDURES; IRS PRIVATE LETTER RULINGS;  AND INTERNAL IRS/TREASURY MEMORANDA INVOLVING COMPLEX ISSUES OF FEDERAL TAXATION.

 

NEW YORK UNIVERSITY SCHOOL OF LAW/INTERNAL REVENUE SERVICE

EDUCATIONAL PROGRAM

17 SEMESTER TAX LAW COURSES

 

PUBLISHED:

JOURNAL OF PARTNERSHIP TAXATION (WG&L)

VOLUME 10, NUMBER 2 (SUMMER 1993)

PARTNERSHIPS WITH TAX-EXEMPT PARTNERS

GIVEN GUIDANCE ON AVOIDING UBTI

SPEAKER AMERICAN BAR ASSOCIATION PARTNERSHIP TAX SECTION