|
|
 |
Areas of Emphasis
- Tax Planning
- Tax Dispute Resolution
- State and Local Taxation
Distinctions
- Fellow, American College of Tax Counsel
- The Best Lawyers in America®, Tax Law, Trusts and Estates
- Mid-South Super Lawyers®, Tax
- Certified Public Accountant (Miss.)
- Mississippi Legal Correspondent, State Tax Notes
- Mississippi Tax Institute
- Board of Trustees, 1993-1995
- AV-rated, Martindale-Hubbell
Education & Honors
- New York University, LL.M., Taxation, 1984
- University of Mississippi, J.D., 1982
- Editorial Board, Mississippi Law Journal
- University of Mississippi, B.B.A., Accounting, 1977
|
|
Associations
- American Bar Association
- Taxation Section
- State and Local Tax Committee
- Institute for Professionals in Taxation
- National Association of Property Tax Attorneys
- Mississippi Bar
- Taxation Section
- Mississippi Society of Certified Public Accountants
- Board of Governors, 1987-89 and 1997-99
Bar Admissions
|
| |
Legal Experience
- Fed Gift Tax Controversy. Representation of taxpayers in U.S. District Court to contest transferee liability for unpaid gift taxes.
- Fed Gift Tax Controversy. Representation of taxpayers before the IRS Appeals Division to defend discounts claimed in connection with the valuations of gifted interests in family limited partnerships.
- Fed Estate Tax Controversy. Representation of estate in the U.S. Tax Court to contest the disallowance of a charitable deduction for a post mortem grant of a conservation easement.
- Fed Income Tax Controversy. Representation of taxpayers before the IRS Appeals Division and the U. S. Tax Court to contest proposed assessments of income tax.
- State Tax Controversy. Representation of multi-state corporaton in Miss. Chancery Court involving the issue of how to apportion income earned from electronic commerce.
- State Tax Controversy. Representation of out-of-state individual taxpayers in multi-million dollar Miss. income tax assessment; taxpayers could not post jurisdictional bond, so relief was secured in TRO action in Miss. Chancery Court resulting in favorable settlement for taxpayers of approximately 25% of original assessment..
- State Tax Controversy. Representation of Fortune 500 company in multi-million dollar income tax assessment and refund action in Miss. Chancery Court resulting in $4,000,000 refund (issue was whether gain on sals of business was business income or nonbusiness income under UDITPA).
- State Tax Controversy. Representation of multi-state corporation seeking refund of state use taxes pursuant to exemption based on payment of sales tax to another state on the same transactionn Weeks Dredging & Contracting, Inc. v. MS State Tax Commission, 521 So. 2d 884 (Miss. 1988).
- State Tax Controversy. Representation of multi-state corporation in Miss. Chancery Court contesting the disallowance of deductions for premiums paid to captive insurance company.
- Tax Deferred Exchanges. Representation of numerous taxpayers in structuring and documenting forward and reverse like kind exchanges of real property.
- Corporate Reorganizations. Representation of numerous corporations in structuring acquisitive and divisive tax-free reorganizations.
- Private letter Rulings. Representation of numerous taxpayers to successfully obtain private letter rulings on various issues from both the IRS and the Miss. State Tax Commission.
Papers, Presentations, & Publications
- “IRS Proposes New ‘Audit Me’ Disclosure Requirement,” Point Innovation, Spring 2010.
- "Summary of First Quarter 2008 Developments in Mississippi Tax Law,"Mississippi Tax Bulletin, April 2008.
- “Summary of 2007 Developments in Mississippi Tax Law,” Mississippi Tax Bulletin, February 2008.
- "Two Recent Mississippi Tax Cases,” Mississippi Tax Bulletin, October 2007.
- “Legislative Developments,” Mississippi Tax Bulletin, June 2007.
- “Unconstitutional Corporate Tax Statutes,” Mississippi Tax Bulletin, October 2006.
- “Mississippi Income Tax Developments,” Mississippi Tax Bulletin, July 2006.
|
|
