Jerry advises businesses and their owners on business tax issues, including the structuring of transactions to achieve optimum tax efficiencies. He also represents businesses and business owners in disputes with tax authorities, both in administrative proceedings and in court.
Jerry graduated with distinction from Georgetown’s Tax LL.M. program, consistently ranked one of the top such programs in the country. But he also has 24 years of experience litigating disputes in the courtroom. He therefore offers both courtroom savvy and top-notch tax law talent.
Jerry advises and represents clients in:
Tax litigation. Representation of individuals and business entities in the U.S. Tax Court and in refund actions in the federal district courts and the Court of Federal Claims.
IRS audits and administrative appeals. Representation of individuals and business entities during IRS audits and IRS administrative appeals.
Tax preparer penalty proceedings. Representation of paid tax preparers in preparer penalty proceedings brought by the IRS.
Employment related tax matters. Representation of business entities and their owners or officers in proceedings arising out of the employer-employee relationship, including trust fund recovery penalty and alleged worker misclassification proceedings.
Multistate sales and income tax compliance. Advising business clients on multistate sales tax and income tax compliance issues, including nexus requirements.
Inbound and outbound international tax planning. Assisting clients in navigating the international tax system, including compliance with transfer pricing regulations, with the goal of lawfully minimizing global tax obligations.
Business transaction planning. Helping clients structure business transactions for optimum tax efficiencies.
- Representation of taxpayers in IRS audits, IRS administrative appeals, and before the U.S. Tax Court.
- Representation of a trust in connection with issues arising out of a potential federal tax lien against trust assets.
- Advising and assisting clients in connection with the successful completion of complex Section 1031 like-kind exchanges.
- Submission of applications for foreign companies or other foreign persons for U.S. employer identification numbers or individual tax identification numbers.
- Advising corporations on state and local sales and use tax issues.
- Advising and assisting foreign investors in connection with FIRPTA, including applications for withholding certificates.
- Representation of multiple taxpayers and third parties in connection with trust fund recovery claims.
- Advising a U.S. tax resident on obligations relating to the reporting of a foreign trust account.
- Advising on, and drafting, transfer pricing agreements for companies engaged in transactions with their U.S. affiliates.
- Assisting a growing biotechnology company with the tax aspects of a corporate restructuring.
- Representation of a taxpayer in proceedings to disqualify a self-directed IRA on allegations that the beneficiary had engaged in prohibited transactions.
- Advising a regional contractor on sales tax collection issues.
- Representing a tax preparer in tax preparer penalty litigation in federal court, resulting in an Order requiring the IRS to pay the preparer’s legal fees on the grounds that the IRS’ position was not substantially justified.
- Preparing and submitting offers in compromise and installment agreement applications for business and individual clients.
- Advising multiple clients on the tax consequences arising out of various potential business sale structures.
- Representation of multiple clients in IRS penalty abatement proceedings.