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Areas of Practice

• Active administrative tax practice dealing with local, state and federal audits, collections and criminal investigations
• Civil and criminal tax litigation in all federal and State of Arizona Courts and appeals therefrom, civil litigation in the United States Tax Court, Federal District Court and the United States Court of Federal Claims
• Arizona Accounting Board representation
• Expert witness testimony
• Entity formations
• White Collar Criminal Litigation

Certified Legal Specialties

• Tax Law Specialist, Board of Legal Specialization of the State Bar of Arizona

Bar Admissions

• Arizona, 1995
• California, 1997
• U.S. District Court Central District of California, 1999
• U.S. District Court Eastern District of California, 2006
• U.S. District Court Southern District of California, 2007
• U.S. District Court Northern District of California, 2007
• U.S. District Court District of Arizona, 2002
• U.S. District Court District of New Mexico, 2022
• U.S. District Court District of Colorado, 2022
• U.S. Court of Appeals 9th Circuit, 1996
• U.S. Court of Appeals Federal Circuit, 2023
• U.S. Court of Appeals 10th Circuit, 2023
• U.S. Court of Federal Claims, 2008
• U.S. Tax Court, 1995
• U.S. Supreme Court, 2007

Education

• Gonzaga University School of Law, Spokane, Washington
  J.D. – May, 1995
• University of Arizona, Tucson, Arizona
  B.S. – May, 1992
  Major: Accounting

Published Works

• Form 8300 and your Car Dealership’s Reporting Requirements
• Why Innocent Spouse Relief Should be Considered in Divorce, June 2003
• The New Tax Law Burden of Proof and Production, May 2002
• A Kinder, Gentler IRS, The Federal Tax Lawyer, assisted in preparation of the article (November/December, 1999)

Representative Cases

• Vensure HR, Inc. v. United States, 2023-1640 (Court of Appeals for the Federal Circuit, 2024)
• Shilgevorkyan v. Commissioner, T.C. Memo. 2023-12 (U.S. Tax Court 2023)
• Norma Slone, Transferee, et al. v. Com­missioner, 896 F.3d 1083 (9th Cir. 2018­)
• Jarnagin v. United States, No. 15-1534T (U.S. Court of Federal Claims 2017)
• Norma Slone, Transferee, et al. v. Commissioner, T.C. Memo. 2016-115 (US Tax Court 2016)
• Norma Slone, Transferee, et al. v. Commissioner, 788 F.3d 1049 (9th Cir. 2015)
• Val-Pak East Valley , Inc. v. Arizona Department of Revenue, 1 CA-TX 10-0005 (Arizona Court of Appeals 2012)
• Norma Slone, Transferee, et al. v. Commissioner, T.C. Memo. 2012-57 (U.S. Tax Court 2012)
• City of Mesa v. Val-Pak East Valley, Inc., 1 CA-TX 08-0010 (Arizona Court of Appeals 2010)
• FRGC Investment, LLC v. Commissioner, aff’d 89 Fed. Appx. 656 (9th Cir. 2004)
• FRGC Investment, LLC v. Commissioner, T.C. Memo. 2002-276 (U.S. Tax Court 2002)
• Chamales v. Commissioner, T.C. Memo. 2000-33 (U.S. Tax Court 2000)
• Brewer v. Commissioner, T.C. Memo. 1997-543 (U.S. Tax Court 1999)
• Wilson v. Commissioner, T.C. Memo. 1999-327 (U.S. Tax Court 1999)
• Paig v. Commissioner, T.C. Summary Opinion 1999-47 (U.S. Tax Court 1999)
• Paig v. Commissioner, Order (U.S. Tax Court 1999)
• Berge v. Commissioner, T.C. Summary Opinion 1999-41 (U.S. Tax Court 1999)
• Steppes v. Commissioner, T.C. Summary Opinion 1998-208 (U.S. Tax Court 1998)
• Guerrero v. Commissioner, T.C. Memo. 1998-221 (U.S. Tax Court 1998)
• Bushey v. Commissioner, T.C. Summary Opinion 1998-150 (U.S. Tax Court 1998)
• Guarna v. Commissioner, T.C. Summary Opinion 1998-94 (U.S. Tax Court 1998)
• Johnson v. Commissioner, Order 1998 (U.S. Tax Court 1998)
• Summers v. Commissioner, Order 1998 (U.S. Tax Court 1998)
• Boatner v. Commissioner, T.C. Memo. 1997-379 (9th Cir. 1998)
• Boatner v. Commissioner, aff’d, 164 F.3d 629 (U.S. Tax Court 1997)
• Chiu v. Commissioner, T.C. Memo. 1997-199 (U.S. Tax Court 1996)
• Levin v. Commissioner, T.C. Memo. 1996-211 (U.S. Tax Court 1996)
• Conrad v. Commissioner, T.C. Summary Opinion 1996-194 (U.S. Tax Court 1996)
• Capka v. Commissioner, T.C. Summary Opinion 1996-194 (U.S. Tax Court 1996)
• Barnhill v. Commissioner, T.C. Memo. 1996-97 (U.S. Tax Court 1996)

Classes/Seminars

• Presenter: COVID Tax Relief Fraud Enforcement, Arizona Forum for Improvement of Taxation, January 27, 2023
• Presenter: IRS and other initiatives in COVID relief (PPP, Employee Retention Credit, Economic Injury Disaster Loans) fraud investigations, along with an increasing number of IRS referrals for criminal prosecution of non-payment of payroll trust fund taxes, Southwest Fest Enrolled Agents, June 16, 2022
• Presenter: IRS Initiatives: High-Income Taxpayers, Arizona Forum for Improvement of Taxation, January 20, 2022
• Presenter: Community Property, Arizona Forum for Improvement of Taxation, January 22, 2021
• Presenter: Cryptocurrency, Arizona Forum for Improvement of Taxation, January 23, 2020
• Presenter: State of Arizona Criminal Tax Issues, Phoenix Tax Workshop, November 16, 2019
• Presenter: FBAR’s and Foreign Transactions, Arizona Society of Enrolled Agents, October 17, 2019
• Presenter: IRS Audit Reconsideration vs. IRS Offer in Compromise Based upon Doubt as to Liability, Arizona Forum for Improvement of Taxation, July 25, 2019
• Presenter: IRS Criminal Enforcement Priorities, Phoenix, Arizona, Arizona Forum for Improvement of Taxation, January 25, 2018
• Presenter: FBAR and Other Foreign Disclosure Requirements, Phoenix, Arizona, Arizona Forum for Improvement of Taxation, January 19, 2017
• Presenter: Conflicts of Interest for Tax Professionals, Phoenix, Arizona, Arizona Forum for Improvement of Taxation, July 21, 2016
• Presenter: Where Did the Money Go, and How Will the Government Find it?, American Bar Association, December 14, 2014
• Presenter: Form 8300 and Your Reporting Requirements/Avoiding Unintentional “Structuring” of Cash Transactions, Arizona Forum for Improvement of Taxation, July 16, 2014
• Presenter: IRS Audits, Arizona Society of Practicing Accountants, East Valley Chapter, August 13, 2013
• Presenter: Worker Classification Issues and Solutions for Employers, January 2013, Arizonans Forum Improvement of Taxation
• Presenter: Tax Issues in a Down Economy, State Bar of Arizona Convention, 2012
• Presenter: The Changing Landscape of Tax Law, Ethics and Professional Responsibility, State Bar of Arizona Convention, 2011
• Presenter: Anatomy of an IRS Field Examination: From Initial Audit Notification to Appeals, Phoenix, Arizona, Arizona Forum for Improvement of Taxation, July 21, 2010
• Presenter: Is Out of State Job Printing Subject to Use Tax? Voluntarily Disclosing Foreign Bank Accounts. Is it safe to do so if you did not file under the IRS Settlement Initiative?, Entrepreneurial CPA Network Meeting, 2010
• Presenter: Indirect Methods of Proof, Arizona Forum for Improvement of Taxation, 2009
• Presenter: ADOR Tax Amnesty and IRS Invited Taxpayers to Disclose Offshore Account; Offer Penalty Abatement, Phoenix Tax Workshop, 2009
• Presenter: Tax Collection Enforcement, Arizona State Bar Association, Convention, 2008
• Presenter: Tax Procedure in Collection Cases, Entrepreneurial CPA Network, 2008
• Presenter: Discussion of Current Developments: Update on Federal Offers in Compromise, Phoenix Tax Workshop, 2008
• Presenter: Unexpected Tax Consequences: Residential Foreclosures and Short-Sales as Forgiveness of Debt, Arizona State Bar Bankruptcy Section, 2008
• Presenter: Federal Trust Fund Taxes, State Bar of Arizona, Presenter, 2007
• Presenter: New IRS Fraud Guidelines in Civil Audits, Phoenix Tax Workshop, 2006
• Presenter: Disregarded Entity or Elect to be Taxed as a S Corporation. Election, Is this the new Planning Vehicle?, Phoenix Tax Workshop, 2004
• Presenter: What to do when you are faced with a Trust Fund (Payroll) Tax Assessment, including Trust Fund Recovery Penalty Interview, Defense and Case Law, Phoenix Tax Workshop, 2004
• Presenter: Effective Tax Planning and Litigation Using IRS Guidance, State Bar of Arizona Seminar, Moderator, 2003
• Presenter: ADOR Amnesty Program to Help Close the Budget Gap?, Phoenix Tax Workshop, 2003
• Presenter: Tax Disputes from Cradle to Grave, State Bar of Arizona Convention, Moderator, 2003
• Presenter: Settling Tax Disputes with the IRS – Is Mediation the Answer?, Phoenix Tax Workshop, 2002
• Presenter: Offers in Compromise and What to Do When the IRS Knocks on Your Door, Arizona Society of Practicing Accountants, 2002
• Presenter: Offers in Compromise, Phoenix Tax Workshop, 2002
• Presenter: The New Tax Court Burden of Proof, A Dangerous Placebo?, Phoenix Tax Workshop, 2001
• Presenter: Criminal Forfeitures, Presented to Criminal Investigation Special Agents, 1999
• Presenter: How to Effectively Audit a Retail Gasoline Station, Presented to specialty group of IRS Revenue Agents, 1997 – 1999
• Presenter: The Tax Audit of a Civil Capper Case, Presented to special group of IRS Revenue Agents, 1998

Honors and Awards

• Fellow, American College of Tax Counsel
• Best Lawyers in America
• Top Arizona Attorneys in Arizona, Arizona Magazine, May 2012
• Southwest Super Lawyers
• Martindale Hubbell AV Rated
• North Valley Magazine Top Lawyers in Tax, October/November 2011
• U.S. News-Best Lawyers, “Best Law Firm” Rankings, Tax Litigation and Tax Law, Tier 1

Professional Associations and Memberships

• California Bar Association
• Phoenix Tax Workshop, Advisory Board, 2002 – Present
• United States Tax Court Judicial Conference, Lawyer Representative
• Arizona State Bar, Tax Section, Chairman, 2010 – 2011
• Arizona State Bar, Tax Section, Program Coordinator
• Arizona State Bar, Tax Section, Member at Large
• Arizona State Bar, Tax Section, Secretary
• Arizona State Bar, Tax Section, Vice President
• Arizona State Bar, Tax Section, Chair Elect
• Arizona Forum for the Improvement of Taxation, Board Member, Vice President, 2012 – 2018, President 2018 – Present

Past Employment Positions

• Kajan, Mather and Barish, A Professional Corporation, Associate, Beverly Hills, California, 1999 – 2000
• Office of Chief Counsel, Internal Revenue Service, Trial Attorney and Criminal Tax Attorney, Los Angeles, California, 1995 – 1999