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.

Experience Center

Match our Experience to Your Needs

Experience Highlights

Patent prosecution and counseling for U.K. Ministry of Defence (MOD)
Represent the U.K. Ministry of Defence (MOD), which is responsible for the military and homeland security functions of the United Kingdom, and have more
Products liability litigation for manufacturing company
The firm served as lead counsel in defending claims based on breach of warranty and negligence allegedly resulting in an explosion at a North more
Investigation for a corporation in response to shareholder demand letter
Conducted investigation for Special Committee of the Board of Directors of a corporation in response to shareholder demand letter. more
Defeasances of billions of dollars of CMBS loans
Represented servicer and special servicer in defeasances of billions of dollars of securitized mortgage loans. more