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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Financing of acquisition made by Reynolds American
Represented Reynolds American Inc. in obtaining $2.1 billion of credit facilities to finance its acquisition of the Conwood Company. more
Criminal liability and government disclosures related to internal computer audits
Advised a Fortune 500 company on criminal liability and government disclosures related to internal computer audits. more
Brownfields agreement for Wake Forest University
Represent property developer, Wake Forest University, in a major research park's negotiations with the North Carolina Department of Environment and more
Trust funds litigation for equitable accounting of lands and resources for a tribal community
Serves as lead counsel representing claims for an equitable accounting of the trust funds, lands and resources the U.S. government has held in trusts more