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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Priority of other insurance coverage for death and bodily injury following a refinery explosion
After the trial court ruled on summary judgment that Citgo, as an "additional insured" under our client’s GLC policy, could obtain $5 million in more
Sale of publicly held Industrial Distribution Group Inc. to a private equity firm
Represented Industrial Distribution Group Inc., a publicly held distributor of industrial supplies, in its acquisition by Eiger Holdco, LLC, an more
Security and privacy provisions for global logistics company
Revision of security and privacy provisions in a form of distribution agreement to be used globally by a global logistics provider. more
Expert witness in litigation for pharmaceutical company
Expert witness for global veterinary medicine corporation in litigation involving an animal vaccine. more