Practice Areas
Tax controversy/disputes before the IRS (at Exam, Appeals, and mediations), and before federal courts; clients include private equity and investment funds, portfolio companies, public companies, partnerships, and high-net-worth individuals in every facet of the tax controversy practice including tax issues in M&A, BBA audits, subchapters C and K, up-C structures, section 382, anti-abuse doctrines, oil and gas, green energy transition/renewable credits, tax insurance issues, liability management transactions, passive activity rules, foreign tax credits, financial products, tax sharing agreements, R&D credits, tax promoter audits, international tax/treaty issues, competent authority/APMA, excise tax issues, tax shelter defense, section 1033 and 1234A issues, casualty loss issues, normalization tax issues, and receivership tax issues; also represents companies/individuals in private-party M&A tax and purchase price disputes before accounting experts, arbitrators, and courts; and consults in negotiating M&A transactions to ensure that tax controversy risk is allocated properly between the parties.
Career
Fellow, American College of Tax Counsel; US Tax Court, US Court of Federal Claims, US Courts of Appeals for the Fifth, Seventh and Federal Circuits; various federal district courts.
Personal
JD, with high honors, University of Chicago Law School, 1991 (Order of the Coif); BS, summa cum laude, first honors mathematics, University of Dallas, 1988. Board member of Houston Grand Opera, University of Dallas, and St Thomas More Society of Galveston-Houston. Knight Commander, Equestrian Order of the Holy Sepulcher of Jerusalem.
