Represented a global manufacturer in a case involving a highly controversial “listed transaction” being challenged by the IRS.  The listed transaction at issue, which initially was undertaken by many corporate taxpayers, involved the client claiming deductions for contributions to its 401k plans prior to the year that employees performed the services giving rise to the contributions. While the weight of authority supported this deduction in the taxpayer's circumstances, the IRS challenged the deduction, labeling it abusive. The team filed a Motion for Partial Summary Judgment, asking the Tax Court to dismiss the IRS's proposed deficiencies relating to the 401k deductions. The IRS agreed to concede the case, dropping its proposed assessments of tax and penalties exceeding $25 million.

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Wetlands enforcement action for architectural and construction building products company
Successfully represented U.S. and Canadian architectural and construction building products company with regard to a wetlands enforcement action more
Construction litigation for international EPC contractor and original equipment manufacturer
The firm served as lead counsel to an international EPC contractor/OEM in multiparty disputes arising out of the construction of an $800 million more
Breach of fiduciary duty case against employee of a Fortune 200 company
Successfully represented a Fortune 200 employer in trial and appeal against a former employee who engaged in self-dealing in breach of his more
Contract dispute for mechanical subcontractor specializing in industrial piping fabrication and erection
Represent a mechanical subcontractor specializing in industrial piping fabrication and erection against a multinational General Works more