Practice Areas
John’s practice focuses on tax and fiduciary litigation. He represents taxpayers in sophisticated estate, gift, and income tax controversy matters, including audits, IRS appeals, and litigation. He also provides legal counsel on estate planning issues for high net-worth individuals to best position their estate plan against IRS challenge. John has served as lead counsel for the taxpayer in some of the most significant published transfer tax decisions in the last twenty-five years, including Anenberg and McDougall (rejecting IRS argument that termination of a QTIP trust and distribution of assets to surviving spouse was a gift by surviving spouse under IRC section 2519) Petter, Christiansen, McCord, and Hendrix (upholding formula clauses used to transfer hard to value assets), Bongard, Stone, Murphy, Black, and Schutt (rejecting IRS attempts to apply IRC section 2036 to family entities), Jelke, Dunn, Kerr, Jameson, Davis and Richmond (built-in capital gains discount when valuing stock), Steinberg (approving the net-net gift discount), and Litman/Diener (valuation of restricted stock and reasonable reliance defense to IRS penalties).
Professional Memberships
John is a fellow of the American College of Trust and Estate Counsel and the American College of Tax Counsel and a board certified specialist in probate, trust and estate law by the Texas Board of Legal Specialization.
Personal
JD (cum laude), Baylor Law School, 1986, BBA, accounting, Texas A&M University, 1982.
