Experience

  • served as class co-counsel in several class action lawsuits, including a successful suit to prevent PTIN fees and require refunds of $270m of PTIN fees paid, and an interpleader action relating to ESOP funds in excess of $200m
  • guided fiduciaries of a publicly-traded company through two company stock retirement plan fund lawsuits with respect to two plans, with no liability to (or settlement by) the fiduciaries, the company or the plans
  • utilized an article to help substantially eliminate the same desk rule and then, with client agreement and IRS permission, charged the time costs of creation to the trust of a plan that significantly benefited from the substantial elimination
  • with help from associates, while a partner at Troutman Sanders LLP, developed a concise, relatively easy-to-read schematic that provided tax, SEC and accounting rules of equity compensation plans
  • represented minority shareholders/LLC members in federal and state courts
  • represented taxpayers in U.S. Tax Court and in federal court on tax matters
  • settled a U.S. Department of Labor audit on plan fees charged to the plan’s trust (that the DOL alleged should have been paid by the sponsor) for 14 percent of the amount alleged to be wrongfully charged
  • authored many articles, primarily on public finances, that have been published in The Atlanta Journal and Constitution
  • in 2008, along with Hayden Kepner and Jay Bookman, debated John Linder, Neal Boortz and Mark Darrow on the Fair Tax bill on CNN
  • interviewed in the documentary An Inconvenient Tax
  • successfully aided persons pursued by the IRS for the responsible person penalty (i.e. the IRC section 6672 penalty)
  • brought three lawsuits to prevent charging of user fees of tax return preparers by the U.S. Treasury Department (third case is pending in U.S. District Court in Washington D.C.)
  • established estate and lifetime plans for many persons and couples, and created related documents
  • formed many companies, including LLCs and corporations (and dissolved many businesses)