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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Litigation for a Georgia healthcare company
Represented a Georgia healthcare company in obtaining summary judgment on behalf of the hospital dismissing antitrust claims of a perinatologist who more
Convinced DOJ not to take action in a theft of trade secret investigation
In less than three months, we convinced the Department of Justice not to take any action against a client employee for allegedly stealing trade more
Initial public offering for Interland Inc.
Represented Interland Inc., a web hosting company, in its $60 million initial public offering. more
Acquisition by pharmaceutical company
Represented pharmaceutical company before the Federal Trade Commission in connection with antitrust merger review.  Advised pharmaceutical company on more