Industry focus
Listening is a communication skill often neglected, especially by lawyers. I strive to listen carefully to each client and respond to their particular needs.
How I represent clients at Schwabe
I help clients resolve “make or break” civil and criminal tax issues in state and federal courts. In my 36-year career, I have obtained successful results for hundreds of clients, including the first award of attorney fees against the Internal Revenue Service under the IRS Restructuring and Reform Act of 1998.
I represent clients in tax and related financial cases before the United States Tax Court, the U.S. District Courts in Oregon, Washington, and California, the U.S. Court of Appeals for the Ninth Circuit and the U.S. Court of Federal Claims, and state courts. I also assist clients with a wide variety of tax matters before administrative agencies in Oregon, Washington, and California.
In addition to my tax controversy and litigation work, since 1980, I have also practiced as a tax planning and transactional tax lawyer. The combination of these two distinct but related areas of tax practice enables me to understand the business aspects of tax controversies and offer unique, creative solutions.
My practice also encompasses non-tax controversies involving import-export regulations, environmental laws, the Endangered Species Act, RICO, and white-collar criminal controversies.
Experience
- Representation of individuals and business entities in the United States Tax Court and the Oregon Tax Court.
- Representation of taxpayers in refund litigation in state and federal courts.
- Representation of taxpayers in criminal tax investigations and criminal tax litigation.
- Property tax valuation and exemption cases in the Oregon Tax Court.
- Administrative representation of taxpayers before the Internal Revenue Service and state taxing agencies in areas including:
-Appeals of proposed tax deficiencies
-Tax collection disputes
-Applications for Innocent Spouse and Injured Spouse relief
-Offers in Compromise
-Installment payment arrangements
-Taxation of settlement awards and judgments in civil litigation
-Taxation of spousal separation awards and settlements
- Represented clients before other federal administrative agencies, including the Bureau of Alcohol, Tobacco and Firearms; the Environmental Protection Agency; the Department of Homeland Security and others.
- Represented clients as plaintiffs in prosecuting defendants for racketeering, the unauthorized practice of law and identity theft matters.
Education
- Loyola University, School of Law Juris Doctor degree (1978)
- Georgetown University, Law Center, Master of Laws degree, Taxation (1980)
- University of Redlands, Bachelor of Science degree (1975)
Admissions
- California State Courts
- Oregon State Courts
- Washington State Courts
- U.S. Court of Appeals - Ninth Circuit
- U.S. Court of Appeals - Federal Circuit
- U.S. Court of Federal Claims
- U.S. District Court - Central District of California
- U.S. District Court - District of Oregon
- U.S. District Court - Eastern District of California
- U.S. District Court - Eastern District of Washington
- U.S. District Court - Northern District of California
- U.S. District Court - Southern District of California
- U.S. District Court - Western District of Washington
- U.S. Tax Courts
- U.S. Supreme Court
Memberships
- Chairman, Section of Taxation, Oregon State Bar, 2007
- President, Beaverton Rotary Club, 1998-1999
Awards
- Award of Merit, Oregon State Bar Taxation Section, 2016
- AV Preeminent Peer Review Rated with Martindale-Hubbell® since 1987
- AV Preeminent Peer Review Rated with Martindale-Hubbell® 20-year recognition
- Best Lawyers in America, “Tax Lawyer of the Year – Tax Litigation and Controversy” (2012 and 2024)
- John L. Schwabe Client Service Award, 2010
- Recognized by The Best Lawyers in America®, Tax Litigation and Controversy & Tax Law (2006-2025)
- Oregon Super Lawyers, Tax (2006-2021)
- Rotarian of the Year, Beaverton, Oregon Rotary, 1994
- Beaverton Rotary Paul Harris Fellowship Award, 1992
Community Activities
- Portland Mountain Rescue, Member (1984-1990)
- Beaverton, Oregon Rotary Club, Member (1987-2013)
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