Head, Tax Controversy practice. Partner since January 2009. Previously IRS Chief Counsel since 2004. Developed litigation strategy behind Government’s successful tax shelter litigation and served as lead negotiator in landmark transfer pricing dispute, resulting in largest single payment ever made to resolve an IRS tax dispute. Earlier IRS service includes leading IRS’s involvement in legislative process that resulted in landmark Tax Reform Act of 1986. Significant private sector experience, most recently at Thompson Hine, developing its tax controversy practice.
Georgetown Law School (LLM, 1977); Case Western Reserve Law School (JD, 1973); John Carroll University (BA, 1970).